State of Utah 

Department of 

Environmental Quality 

Dianne R. Nielson, Ph.D. 

Executive Director 

DIVISION OF AIR QUALITY 

Richard W. Sprott 

Director

JON M. HUNTSMAN, JR. 

Governor 

GARY HERBERT 

Lieutenant Governor

Site ID: 10303

Title V Operating Permit 

PERMIT NUMBER: 2300015002 

DATE OF PERMIT: December 1, 2006 

Date of Last Revision: December 1, 2006 

This Operating Permit is issued to, and applies to the following: 

Name of Permittee: 

Ash Grove Cement Company 

PO Box 51 

Nephi, UT 84648 

Permitted Location: 

Leamington Cement Plant 

Hwy 132 

Leamington, UT 84638 

UTM coordinates: 4,379,850 meters Northing, 397,300 meters Easting 

SIC code: 3241 

ABSTRACT 

Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab County, Utah. 

This plant has been in operation since 1981. At the Leamington cement plant, cement is produced when 

inorganic raw materials, primarily limestone (quarried on site), are correctly proportioned, ground and 

mixed, and then fed into a rotating kiln. The kiln alters the materials and recombines them into small 

stones called cement clinker. The clinker is cooled and ground with gypsum and additional limestone 

into a fine powdered cement. The final product is stored on site for later shipping. The major sources of 

air emissions are from the combustion of fuels for the kiln operation, from the kiln, and from the clinker 

cooling process. The Leamington cement plant is a major source for emissions of PM10, NOx, and CO, 

and is subject to NSPS Subparts A, Y, & OOO, and NESHAP Subparts A & LLL. 

UTAH AIR QUALITY BOARD 

By: Prepared By: 

Richard W. Sprott, Executive Secretary Brandy Cannon 

150 North 1950 West • PO Box 144820 • Salt Lake City, UT 84114-4820 • phone (801) 536-4000 • fax (801) 536-4099 

T.D.D. (801) 536-4414 • www.deq.utah.gov
Operating Permit History 

1/5/2000 - Permit issued Action initiated by an initial 

operating permit application 

12/24/2003 -Permit modified Action initiated by an 

administrative amendment 

(initiated by source) 

To add the cross-belt analyzer 

approved in DAQE-AN0303009-03 

and incorporate limit changes from 

DAQE-AN0303006-03. In addition, a 

number of small changes or 

corrections were made. These result 

from minor changes in previously 

listed equipment and to correct 

typographical errors. 

7/29/2005 -Permit modified Action initiated by an 

administrative amendment 

(initiated by DAQ) 

To incorporate changes approved in 

DAQE-AN0303011-05, dated May 20, 

2005, including the following: 

installation of a limestone bypass 

system to incorporate additional 

limestone into the clinker and gypsum 

prior to the finish mill, addition of two 

new baghouses associated with the 

limestone bypass system located at the 

new limestone silo and conveyor, and 

replacement of two baghouses 

(419.BF4, 419.BF5) controlling 

discharge from the east and west 

clinker belts into the clinker storage 

silos. Additional permit changes 

include: correction of typographical 

errors, update of emission unit 

identification numbers, and revision of 

the SSMP and O&M plan conditions to 

more closely reflect MACT language. 

12/1/2006 - Permit issued Action initiated by a renewal of 

an operating permit 
Table of Contents 

SECTION I: GENERAL PROVISIONS .................................................................................................. 1

I.A. FEDERAL ENFORCEMENT..............................................................................................................1

I.B. PERMITTED ACTIVITY(IES). ..........................................................................................................1

I.C. DUTY TO COMPLY. .......................................................................................................................1

I.D. PERMIT EXPIRATION AND RENEWAL............................................................................................2

I.E. APPLICATION SHIELD. ..................................................................................................................2

I.F. SEVERABILITY. .............................................................................................................................2

I.G. PERMIT FEE...................................................................................................................................2

I.H. NO PROPERTY RIGHTS..................................................................................................................2

I.I. REVISION EXCEPTION. ..................................................................................................................2

I.J. INSPECTION AND ENTRY...............................................................................................................2

I.K. CERTIFICATION. ............................................................................................................................3

I.L. COMPLIANCE CERTIFICATION.......................................................................................................3

I.M. PERMIT SHIELD.............................................................................................................................4

I.N. EMERGENCY PROVISION...............................................................................................................4

I.O. OPERATIONAL FLEXIBILITY..........................................................................................................5

I.P. OFF-PERMIT CHANGES..................................................................................................................5

I.Q. ADMINISTRATIVE PERMIT AMENDMENTS. ...................................................................................5

I.R. PERMIT MODIFICATIONS...............................................................................................................5

I.S. RECORDS AND REPORTING. ..........................................................................................................5

I.T. REOPENING FOR CAUSE. ...............................................................................................................7

I.U. INVENTORY REQUIREMENTS. .......................................................................................................7

SECTION II: SPECIAL PROVISIONS...................................................................................................8

II.A. EMISSION UNIT(S) PERMITTED TO DISCHARGE AIR CONTAMINANTS..........................................8

II.B. REQUIREMENTS AND LIMITATIONS.............................................................................................10

II.B.1 Conditions on permitted source (Source-wide)............................................................... 10

II.B.2 Conditions on Stationary Crusher (211.BF1).................................................................. 19

II.B.3 Conditions on Raw Material Transfer (211.BF2) ........................................................... 23

II.B.4 Conditions on Coal Grinding System (41B.BF2) ............................................................ 24

II.B.5 Conditions on Coal Silo (41B.BF1)................................................................................... 26

II.B.6 Conditions on Kiln & Pre-Calciner and Raw Mill (317.BF1)........................................ 26

II.B.7 Conditions on Clinker Cooler (419.BF1) ......................................................................... 38

II.B.8 Conditions on Finish Mill (514.BF2) ................................................................................ 41

II.B.9 Conditions on Finish Mill Separator (514.BF1).............................................................. 44

II.B.10 Conditions on Materials Handling Operation (MHO) ................................................... 48

II.B.11 Conditions on Limestone Bypass System (LBS).............................................................. 50

II.B.12 Conditions on Belt Conveyor Transfer Baghouse (311.BC1)......................................... 51

II.C. EMISSIONS TRADING...................................................................................................................52

II.D. ALTERNATIVE OPERATING SCENARIOS......................................................................................52

SECTION III: PERMIT SHIELD...........................................................................................................52

SECTION IV: ACID RAIN PROVISIONS............................................................................................53
Issued under authority of Utah Code Ann. Section 19-2-104 and 19-2-109.1, and in accordance 

with Utah Administrative Code R307-415 Operating Permit Requirements. 

All definitions, terms and abbreviations used in this permit conform to those used in Utah 

Administrative Code R307-101 and R307-415 (Rules), and 40 Code of Federal Regulations (CFR), 

except as otherwise defined in this permit. Unless noted otherwise, references cited in the permit 

conditions refer to the Rules. 

Where a permit condition in Section I, General Provisions, partially recites or summarizes an 

applicable rule, the full text of the applicable portion of the rule shall govern interpretations of the 

requirements of the rule. In the case of a conflict between the Rules and the permit terms and 

conditions of Section II, Special Provisions, the permit terms and conditions of Section II shall govern 

except as noted in Provision I.M, Permit Shield. 

Section I: General Provisions

I.A. Federal Enforcement. 

All terms and conditions in this permit, including those provisions designed to limit the potential 

to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990 (CAA) except 

those terms and conditions that are specifically designated as "State Requirements". (R307-415-

6b) 

I.B. Permitted Activity(ies). 

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance with 

this permit. (See also Provision I.E, Application Shield) 

I.C. Duty to Comply. 

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit 

noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of the 

following: enforcement action; permit termination; revocation and reissuance; modification; or 

denial of a permit renewal application. (R307-415-6a(6)(a)) 

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of this permit. (R307-415-6a(6)(b)) 

I.C.3 The permittee shall furnish to the Executive Secretary, within a reasonable time, any information 

that the Executive Secretary may request in writing to determine whether cause exists for 

modifying, revoking and reissuing, or terminating this permit or to determine compliance with 

this permit. Upon request, the permittee shall also furnish to the Executive Secretary copies of 

records required to be kept by this permit or, for information claimed to be confidential, the 

permittee may furnish such records directly to the EPA along with a claim of confidentiality. 

(R307-415-6a(6)(e)) 

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The 

filing of a request by the permittee for a permit modification, revocation and reissuance, or 

termination, or of a notification of planned changes or anticipated noncompliance shall not stay 

any permit condition, except as provided under R307-415-7f(1) for minor permit modifications. 

(R307-415-6a(6)(c)) 

Issued December 1, 2006 Page 1 Title V Operating Permit #2300015002 
I.D. Permit Expiration and Renewal. 

I.D.1 This permit is issued for a fixed term of five years and expires on December 1, 2011. (R307-

415-6a(2)) 

I.D.2 Application for renewal of this permit is due by June 1, 2011. An application may be submitted 

early for any reason. (R307-415-5a(1)(c)) 

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for 

processing, but shall not be considered a timely application and shall not relieve the permittee of 

any enforcement actions resulting from submitting a late application. (R307-415-5a(5)) 

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete renewal 

application is submitted consistent with R307-415-7b (see also Provision I.E, Application Shield) 

and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2)) 

I.E. Application Shield. 

If the permittee submits a timely and complete application for renewal, the permittee's failure to 

have an operating permit will not be a violation of R307-415, until the Executive Secretary takes 

final action on the permit renewal application. In such case, the terms and conditions of this 

permit shall remain in force until permit renewal or denial. This protection shall cease to apply if, 

subsequent to the completeness determination required pursuant to R307-415-7a(3), and as 

required by R307-415-5a(2), the applicant fails to submit by the deadline specified in writing by 

the Executive Secretary any additional information identified as being needed to process the 

application. (R307-415-7b(2)) 

I.F. Severability. 

In the event of a challenge to any portion of this permit, or if any portion of this permit is held 

invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5)) 

I.G. Permit Fee. 

I.G.1 The permittee shall pay an annual emission fee to the Executive Secretary consistent with R307-

415-9. (R307-415-6a(7)) 

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source 

receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a)) 

I.H. No Property Rights. 

This permit does not convey any property rights of any sort, or any exclusive privilege. (R307-

415-6a(6)(d)) 

I.I. Revision Exception. 

No permit revision shall be required, under any approved economic incentives, marketable 

permits, emissions trading and other similar programs or processes for changes that are provided 

for in this permit. (R307-415-6a(8)) 

I.J. Inspection and Entry. 

Issued December 1, 2006 Page 2 Title V Operating Permit #2300015002 
I.J.1 Upon presentation of credentials and other documents as may be required by law, the permittee 

shall allow the Executive Secretary or an authorized representative to perform any of the 

following: 

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related 

activity is conducted, or where records are kept under the conditions of this permit. 

(R307-415-6c(2)(a)) 

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of this permit. (R307-415-6c(2)(b)) 

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practice, or operation regulated or required under this 

permit. (R307-415-6c(2)(c)) 

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of 

assuring compliance with this permit or applicable requirements. (R307-415-6c(2)(d)) 

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be 

made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e)) 

I.K. Certification. 

Any application form, report, or compliance certification submitted pursuant to this permit shall 

contain certification as to its truth, accuracy, and completeness, by a responsible official as 

defined in R307-415-3. This certification shall state that, based on information and belief formed 

after reasonable inquiry, the statements and information in the document are true, accurate, and 

complete. (R307-415-5d) 

I.L. Compliance Certification. 

I.L.1 Permittee shall submit to the Executive Secretary an annual compliance certification, certifying 

compliance with the terms and conditions contained in this permit, including emission limitations, 

standards, or work practices. This certification shall be submitted no later than January 30, 2007

and that date each year following until this permit expires. The certification shall include all the 

following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5)) 

I.L.1.a The identification of each term or condition of this permit that is the basis of the 

certification; 

I.L.1.b The identification of the methods or other means used by the permittee for determining 

the compliance status with each term and condition during the certification period. Such 

methods and other means shall include, at a minimum, the monitoring and related 

recordkeeping and reporting requirements in this permit. If necessary, the permittee also 

shall identify any other material information that must be included in the certification to 

comply with section 113(c)(2) of the Act, which prohibits knowingly making a false 

certification or omitting material information; 

I.L.1.c The status of compliance with the terms and conditions of the permit for the period 

covered by the certification, including whether compliance during the period was 

continuous or intermittent. The certification shall be based on the method or means 

Issued December 1, 2006 Page 3 Title V Operating Permit #2300015002 
designated in Provision I.L.1.b. The certification shall identify each deviation and take it 

into account in the compliance certification. The certification shall also identify as 

possible exceptions to compliance any periods during which compliance is required and 

in which an excursion or exceedance as defined under 40 CFR Part 64 occurred; and 

I.L.1.d Such other facts as the Executive Secretary may require to determine the compliance 

status. 

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the 

following address or to such other address as may be required by the Executive Secretary: 

(R307-415-6c(5)(d)) 

Office of Enforcement, Compliance and Environmental Justice 

(Mail code 8ENF) 

EPA, Region VIII 

999 18th Street, Suite 300 

Denver, CO 80202-2466 

I.M. Permit Shield. 

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any applicable 

requirements as of the date of this permit, provided that: 

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, 

or (R307-415-6f(1)(a)) 

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in 

this permit. (R307-415-6f(1)(b)) 

I.M.2 Nothing in this permit shall alter or affect any of the following: 

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, 

and the provisions of the CAA Section 303. (R307-415-6f(3)(a)) 

I.M.2.b The liability of the owner or operator of the source for any violation of applicable 

requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior 

to or at the time of issuance of this permit. (R307-415-6f(3)(b) 

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 

408(a). (R307-415-6f(3)(c)) 

I.M.2.d The ability of the Executive Secretary to obtain information from the source under Utah 

Code Ann. Section 19-2-120, and the ability of the EPA to obtain information from the 

source under the CAA Section 114. (R307-415-6f(3)(d)) 

I.N. Emergency Provision. 

I.N.1 An “emergency” is any situation arising from sudden and reasonably unforeseeable events 

beyond the control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation, and that causes the source to exceed a technologyIssued December 1, 2006 Page 4 Title V Operating Permit #2300015002 
based emission limitation under this permit, due to unavoidable increases in emissions 

attributable to the emergency. An emergency shall not include noncompliance to the extent 

caused by improperly designed equipment, lack of preventive maintenance, careless or improper 

operation, or operator error. (R307-415-6g(1)) 

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance with 

such technology-based emission limitations if the affirmative defense is demonstrated through 

properly signed, contemporaneous operating logs, or other relevant evidence that: 

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency. 

(R307-415-6g(3)(a)) 

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b)) 

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize 

levels of emissions that exceeded the emission standards, or other requirements in this 

permit. (R307-415-6g(3)(c)) 

I.N.2.d The permittee submitted notice of the emergency to the Executive Secretary within two 

working days of the time when emission limitations were exceeded due to the emergency. 

This notice must contain a description of the emergency, any steps taken to mitigate 

emissions, and corrective actions taken. This notice fulfills the requirement of Provision 

I.S.2.c below. (R307-415-6g(3)(d)) 

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an 

emergency has the burden of proof. (R307-415-6g(4)) 

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any 

other section of this permit. (R307-415-6g(5)) 

I.O. Operational Flexibility. 

Operational flexibility is governed by R307-415-7d(1). 

I.P. Off-permit Changes. 

Off-permit changes are governed by R307-415-7d(2). 

I.Q. Administrative Permit Amendments. 

Administrative permit amendments are governed by R307-415-7e. 

I.R. Permit Modifications. 

Permit modifications are governed by R307-415-7f. 

I.S. Records and Reporting. 

I.S.1 Records. 

I.S.1.a The records of all required monitoring data and support information shall be retained by 

the permittee for a period of at least five years from the date of the monitoring sample, 

Issued December 1, 2006 Page 5 Title V Operating Permit #2300015002 
measurement, report, or application. Support information includes all calibration and 

maintenance records, all original strip-charts or appropriate recordings for continuous 

monitoring instrumentation, and copies of all reports required by this permit. (R307-415-

6a(3)(b)(ii) 

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source 

shall record the following information, where applicable: (R307-415-6a(3)(b)(i)) 

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement. 

I.S.1.b.2 The date analyses were performed. 

I.S.1.b.3 The company or entity that performed the analyses. 

I.S.1.b.4 The analytical techniques or methods used. 

I.S.1.b.5 The results of such analyses. 

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement. 

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special 

Provisions. 

I.S.2 Reports. 

I.S.2.a Monitoring reports shall be submitted to the Executive Secretary every six months, or 

more frequently if specified in Section II. All instances of deviation from permit 

requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i)) 

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible 

official in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i) 

I.S.2.c The Executive Secretary shall be notified promptly of any deviations from permit 

requirements including those attributable to upset conditions as defined in this permit, the 

probable cause of such deviations, and any corrective actions or preventative measures 

taken. Prompt, as used in this condition, shall be defined as written notification 

within 14 days. Deviations from permit requirements due to unavoidable breakdowns 

shall be reported in accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii)) 

I.S.3 Notification Addresses. 

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to 

the Executive Secretary are to be sent to the following address or to such other address as 

may be required by the Executive Secretary: 

Utah Division of Air Quality 

P.O. Box 144820 

Salt Lake City, UT 84114-4820 

Phone: 801-536-4000 

Issued December 1, 2006 Page 6 Title V Operating Permit #2300015002 
I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to 

the EPA should be sent to one of the following addresses or to such other address as may 

be required by the Executive Secretary: 

For annual compliance certifications For reports, notifications, or other correspondence 

related to permit modifications, applications, etc.

Environmental Protection Agency, Region VIII 

Office of Enforcement, Compliance and 

Environmental Justice (mail code 8ENF) 

999 18th Street, Suite 300 

Denver, CO 80202-2466 

Environmental Protection Agency, Region VIII 

Office of Partnerships & Regulatory Assistance 

Air & Radiation Program (mail code 8P-AR) 

999 18th Street, Suite 300 

Denver, CO 80202-2466 

Phone: 303-312-6440 

I.T. Reopening for Cause. 

I.T.1 A permit shall be reopened and revised under any of the following circumstances: 

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining 

permit term of three or more years. No such reopening is required if the effective date of 

the requirement is later than the date on which this permit is due to expire, unless the 

terms and conditions of this permit have been extended pursuant to R307-415-7c(3), 

application shield. (R307-415-7g(1)(a)) 

I.T.1.b The Executive Secretary or EPA determines that this permit contains a material mistake 

or that inaccurate statements were made in establishing the emissions standards or other 

terms or conditions of this permit. (R307-415-7g(1)(c)) 

I.T.1.c EPA or the Executive Secretary determines that this permit must be revised or revoked to 

assure compliance with applicable requirements. (R307-415-7g(1)(d)) 

I.T.1.d Additional applicable requirements are to become effective before the renewal date of 

this permit and are in conflict with existing permit conditions. (R307-415-7g(1)(e)) 

I.T.2 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial 

permit issuance and shall affect only those parts of this permit for which cause to reopen exists. 

(R307-415-7g(2)) 

I.U. Inventory Requirements. 

Emission inventories shall be submitted in accordance with the procedures of R307-150, 

Emission Inventories. (R307-150) 

Issued December 1, 2006 Page 7 Title V Operating Permit #2300015002 
Section II: SPECIAL PROVISIONS

II.A. Emission Unit(s) Permitted to Discharge Air Contaminants. 

(R307-415-4(3)(a) and R307-415-4(4)) 

II.A.1 Quarry Operations (designated as Quarry) 

Unit Description: Rock drilling operations, truck hauling, and storage piles. No unitspecific applicable requirements. 

II.A.2 Stationary Crusher (designated as 211.BF1) 

Unit Description: Stationary crusher with an approximate production rate of 1,000 tons 

per hour, for reduction of quarried material to 3 inch minus sized material. The crusher is 

equipped with a baghouse and with water sprays on the feed hopper. (pre-1983) 

II.A.3 Raw Material Transfer (designated as 211.BF2) 

Unit Description: Crushed material is transported to raw material storage by belt B8. The 

raw material transfers at the end of conveyor B8 prior to loading into raw material 

reclaim area. The conveyor transfer point is equipped with a baghouse & water sprays. 

(pre-1983) 

II.A.4 Raw Material Silos (designated as 315.SX1 thru 4) 

Unit Description: Raw materials such as limestone, silica, iron, and shale are stored in 

one of four silos. The four silos are equipped with one common baghouse. 

II.A.5 Fifth Component Silo (designated as 315.BF2) 

Unit Description: Raw materials are stored in a silo. This silo is equipped with a 

baghouse. 

II.A.6 Kiln Feed Blending Silos (2) (designated as 411.BF1 and 2) 

Unit Description: Raw material is blended in one of two blending silos prior to feeding 

the kiln. The blending silos are controlled by one common baghouse. 

II.A.7 Blending Silo Elevators (2) (designated as 412.BF1 and 2) 

Unit Description: Blended kiln feed is transferred to the kiln by bucket elevators. The 

elevators are equipped with a baghouse. 

II.A.8 Coal Grinding System (designated as 41B.BF2) 

Unit Description: Coal is ground in a coal mill. Gases drawn from the preheater for the 

kiln entrain the coal in the mill and are dedusted in a baghouse. 

II.A.9 Coal Silo (designated as 41B.BF1) 

Unit Description: Storage of coal for grinding to powder, which is subsequently fired in 

the kiln and calciner. The coal storage silo is equipped with a baghouse. 

II.A.10 Kiln & Pre-Calciner and Raw Mill (designated as 317.BF1) 

Unit Description: Kiln burning process, calciner, and preheater tower off gases are 

directed through the bottom of the raw mill where finely ground raw material is picked 

up. Combustion gases and fine raw materials are then vented to a baghouse. 

II.A.11 Raw Mill Recirculation (designated as 316.BF1 thru 5) 

Unit Description: Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor 

system, and surge bin. Emissions are controlled by five equivalent baghouses. 

II.A.12 Cross-Belt Analyzer (designated as 316.BF6) 

Unit Description: Used for quality control. Emissions are controlled by a baghouse. 

II.A.13 Kiln Feed Alleviator (designated as 414.BF1) 

Unit Description: A baghouse controls particulate from the central material silo between 

the blending silos and the preheater. Raw feed is removed from the system near the top 

of the preheater tower. 

Issued December 1, 2006 Page 8 Title V Operating Permit #2300015002 
II.A.14 Clinker Cooler (designated as 419.BF1) 

Unit Description: Grate type cooler used for cooling clinker from the kiln prior to transfer 

to clinker storage. The clinker cooler vent air is controlled by a baghouse. 

II.A.15 Clinker Belt Transfer (designated as 419.BF8) 

Unit Description: Clinker is removed from the clinker cooler by drag chains and dropped 

onto one of the clinker conveyor belts. The transfer points are controlled by a baghouse. 

II.A.16 East Clinker Belt (designated as 419.BF4) 

Unit Description: Clinker from the clinker cooler is transferred into the East clinker silo 

by conveyor belt. The discharge from the belt is controlled by a baghouse. 

II.A.17 West Clinker Belt (designated as 419.BF5) 

Unit Description: Clinker from the clinker cooler is transferred into the West clinker silo 

by conveyor belt. The discharge from the belt is controlled by a baghouse. 

II.A.18 Clinker Silos (designated as 511.BF2 and 3) 

Unit Description: Clinker from the clinker cooler is transferred to one of three storage 

silos. Each clinker storage silo is equipped with a baghouse to control emissions when 

loading. 

II.A.19 Clinker Reclaim Hopper (designated as 511.BF1) 

Unit Description: Imported clinker is fed to the clinker tunnel conveyor belt by the 

outside clinker hopper. Emissions during transfer of clinker to the conveyor are 

controlled by a baghouse that discharges into the clinker tunnel. 

II.A.20 East Clinker Silo Discharge (designated as 511.BF2) 

Unit Description: Produced clinker is fed to the clinker tunnel conveyor belt from the 

East clinker storage silo. Emissions during transfer of clinker to the conveyor are 

controlled by a baghouse that discharges into the clinker tunnel. 

II.A.21 West Clinker Silo Discharge (designated as 511.BF3) 

Unit Description: Produced clinker is fed to the clinker tunnel conveyor belt from the 

West clinker storage silo. Emissions during transfer of clinker to the conveyor are 

controlled by a baghouse that discharges into the clinker tunnel. 

II.A.22 Gypsum Silo Discharge (designated as 511.BF4) 

Unit Description: Gypsum is fed to the clinker tunnel conveyor belt from the gypsum 

storage silo. Emissions during transfer of gypsum to the conveyor are controlled by a 

baghouse that discharges into the clinker tunnel. 

II.A.23 Clinker Tunnel Exitway (designated as 511.BF1 thru 4) 

Unit Description: The clinker reclaim hopper baghouse (511.BF1), east clinker silo 

baghouse (511.BF2), west clinker silo baghouse (511.BF3), and gypsum silo baghouse 

(511.BF4) all discharge in the clinker tunnel. Emissions are discharged through the 

tunnel exitway. 

II.A.24 Gypsum Silo (designated as 512.SX1) 

Unit Description: Gypsum is stored in the gypsum storage silo. A baghouse is installed 

on the gypsum storage silo to control dust during loading. 

II.A.25 Finish Mill (designated as 514.BF2) 

Unit Description: The finish mill grinds clinker and gypsum to produce finished cement 

product. Dust generated during milling is captured by a baghouse. 

II.A.26 Finish Mill Separator (designated as 514.BF1) 

Unit Description: After clinker and gypsum are ground into cement product, a separator 

returns the oversized cement particles to the finish mill. Dust generated by the finish mill 

separator is collected by a baghouse. 

II.A.27 Finish Cement Storage Silos (designated as 611.BF1) 

Unit Description: There are six storage and two interstice silos where the finished cement 

product is stored. A single common baghouse is located on top of the silos and is used to 

control emissions during loading and unloading operations. 

Issued December 1, 2006 Page 9 Title V Operating Permit #2300015002 
II.A.28 North Cement Load Out (designated as 611.BF2) 

Unit Description: The cement loadout system located on the North side of the silos (rail 

load out side) is controlled by a baghouse during unloading from the silos for rail 

shipping. 

II.A.29 South Cement Load Out (designated as 611.BF3) 

Unit Description: The cement loadout system located on the South side of the silos (truck 

load out side) is controlled by a baghouse during unloading from the silos for truck 

shipping. 

II.A.30 Materials Handling Operation (designated as MHO) 

Unit Description: Includes the following emission units: 315.SX1 thru 4; 315.BF2; 

316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 419.BF4; 

419.BF5; 511.BF2 & 3; 511.BF1 thru 4; 512.SX1; 611.BF1; 611.BF2; 611.BF3; 512.BF2 

& 3. 

II.A.31 Limestone Bypass System (designated as LBS) 

Unit Description: Additional limestone is added to the clinker and gypsum by the 

limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions 

are controlled by water sprays at the screen and material handling drop points. 

II.A.32 Limestone Silo & Belt (designated as 512.BF2 and 3) 

Unit Description: Limestone is stored in the limestone storage silo and transferred to the 

finish mill by conveyor belt. Emissions from the silo and conveyor are controlled by two 

baghouses. 512.BF2 discharges in the clinker tunnel. 512.BF3 is located on top of the 

silo. 

II.A.33 Belt Conveyor Transfer Baghouse (designated as 311.BC1) 

Unit Description: Located prior to raw materials processing, this baghouse controls 

emissions from the conveyor belt that transfers the stacked material to the raw material 

silos. 

II.B. Requirements and limitations. 

The following emission limitations, standards, and operational limitations apply to the permitted 

facility as indicated: (R307-415-6a(1)) 

II.B.1 Conditions on permitted source (Source-wide)

II.B.1.a Condition: 

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, 

to the extent practicable, maintain and operate any permitted plant equipment, including 

associated air pollution control equipment, in a manner consistent with good air pollution 

control practice for minimizing emissions. Determination of whether acceptable 

operating and maintenance procedures are being used will be based on information 

available to the Executive Secretary which may include, but is not limited to, monitoring 

results, opacity observations, review of operating and maintenance procedures, and 

inspection of the source. [Authority granted under R307-401-8(2) and 40 CFR 60.11(d) 

and 40 CFR 63.6 (Subpart A); condition originated in DAQE-AN0303012-06] 

II.B.1.a.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

Issued December 1, 2006 Page 10 Title V Operating Permit #2300015002 
II.B.1.a.2 Recordkeeping: 

Permittee shall document activities performed to assure proper operation and 

maintenance. Records shall be maintained in accordance with Provision I.S.1 of 

this permit. 

II.B.1.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.1.b Condition: 

The permittee shall comply with the applicable requirements for recycling and emission 

reduction for class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - 

Recycling and Emissions Reduction. [Authority granted under 40 CFR 82.150(b); 

condition originated in 40 CFR 82] 

II.B.1.b.1 Monitoring: 

The permittee shall certify, in the annual compliance statement required in 

Section I of this permit, its compliance status with the requirements of 40 CFR 

82, Subpart F. 

II.B.1.b.2 Recordkeeping: 

All records required in 40 CFR 82, Subpart F shall be maintained consistent with 

the requirements of Provision S.1 in Section I of this permit. 

II.B.1.b.3 Reporting: 

All reports required in 40 CFR 82, Subpart F shall be submitted as required. 

There are no additional reporting requirements except as outlined in Section I of 

this permit. 

II.B.1.c Condition: 

The permittee shall comply with the applicable requirements for servicing of motor 

vehicle air conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle 

Air Conditioners. [Authority granted under 40 CFR 82.30(b); condition originated in 40 

CFR 82] 

II.B.1.c.1 Monitoring: 

The permittee shall certify, in the annual compliance statement required in 

Section I of this permit, its compliance status with the requirements of 40 CFR 

82, Subpart B. 

II.B.1.c.2 Recordkeeping: 

All records required in 40 CFR 82, Subpart B shall be maintained consistent with 

the requirements of Provision S.1 in Section I of this permit. 

II.B.1.c.3 Reporting: 

All reports required in 40 CFR 82, Subpart B shall be submitted as required. 

There are no additional reporting requirements except as outlined in Section I of 

this permit. 

Issued December 1, 2006 Page 11 Title V Operating Permit #2300015002 
II.B.1.d Condition: 

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified 

in this permit. [Authority granted under R307-201-3(2); condition originated in R307-

201-3(2) & DAQE-AN0303012-06] 

II.B.1.d.1 Monitoring: 

(a) The permittee shall conduct a monthly 1-minute visible emissions test of 

each affected source in accordance with 40 CFR 60, Appendix A, Method 

22. The test must be conducted while the affected source is in operation. 

(b) If no visible emissions are observed in six consecutive monthly tests for any 

affected source, the permittee may decrease the frequency of testing from 

monthly to semi-annually for that affected source. If visible emissions are 

observed during any semi-annual test, the permittee must resume testing of 

that affected source on a monthly basis and maintain that schedule until no 

visible emissions are observed in six consecutive monthly tests. 

(c) If no visible emissions are observed during the semi-annual test for any 

affected source, the permittee may decrease the frequency of testing from 

semiannually to annually for that affected source. If visible emissions are 

observed during any annual test, the permittee shall resume testing of that 

affected source on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. 

(d) If visible emissions are observed during any Method 22 test, the permittee 

shall conduct a 

i. six minute test of opacity in accordance with 40 CFR 60, Appendix A, 

Method 9 for point sources, or 

ii. one minute test of opacity with five second observation intervals in 

accordance with 58 FR 61640 Method 203C for fugitive emission 

sources. 

The Method 9 or 203C test must begin within one hour of any observation of 

visible emissions. 

II.B.1.d.2 Recordkeeping: 

Records of visible emission tests performed and data required by 40 CFR 60, 

Appendix A, Method 22, Method 9, or 58 FR 61640, Method 203C shall be 

maintained in accordance with Provision I.S.1 of this permit. 

II.B.1.d.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.1.e Condition: 

All unpaved roads, other unpaved operational areas that are used by mobile equipment, 

and all disturbed surfaces not involved with operations shall be water sprayed and/or 

chemically treated to control fugitive dust. Treatment shall be of sufficient frequency and 

quantity to minimize fugitive dust as necessary to meet any applicable opacity limitations 

of this permit. The permittee is not required to apply water to surfaces during freezing 

conditions. If chemical treatment is to be used, the plan shall be pre-approved by the 

Executive Secretary. [Authority granted under R307-401-8(1)(a) [BACT]; condition 

originated in DAQE-AN0303012-06] 

Issued December 1, 2006 Page 12 Title V Operating Permit #2300015002 
II.B.1.e.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.1.e.2 Recordkeeping: 

Instances of water and/or chemical application to unpaved areas shall be recorded 

and maintained by the permittee. The ambient temperature shall be recorded any 

time water should be applied but can not be due to freezing conditions. 

II.B.1.e.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.1.f Condition: 

All paved roads and paved operational areas shall be swept and/or water sprayed to 

minimize fugitive dust. The sweeping and/or water spray shall be conducted as dry 

conditions warrant or as determined necessary by the Executive Secretary. [Authority 

granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-

06] 

II.B.1.f.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.1.f.2 Recordkeeping: 

Instances of each sweeping event or water application to the paved areas shall be 

recorded and maintained by the permittee. 

II.B.1.f.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.1.g Condition: 

For all emission units subject to 40 CFR 63 Subpart LLL: 

The permittee shall prepare and implement an operation and maintenance (O & M) plan 

in accordance with 40 CFR 63.1350(a). The plan shall include the following elements: 

(A) Procedures for proper operation and maintenance of the affected source and air 

pollution control devices in order to meet the emission and operating limits of this 

permit. 

(B) Corrective actions to be taken if visible emissions are observed from the raw mill and 

finish mill sweep and air separator pollution control devices during a daily Method 

22 test. 

(C) Procedures to be used during an inspection of the components of the combustion 

system of the in-line kiln/raw mill which is to be performed at least once per year. 

(D) Procedures to be used to periodically monitor affected sources other than in-line 

kiln/raw mills, clinker coolers, and finish mills which are subject to opacity 

standards. 

Issued December 1, 2006 Page 13 Title V Operating Permit #2300015002 
Failure to comply with any provision of the operations and maintenance plan shall be a 

violation of the standard. [Authority granted under 40 CFR 63.1350; condition originated 

in 40 CFR 63 (Subpart LLL)] 

II.B.1.g.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.1.g.2 Recordkeeping: 

The permittee shall maintain files of all information (including all reports and 

notifications) required by this condition in a form suitable and readily available 

for expeditious inspection and review. These files shall be retained for at least 

five years following the date of each occurrence, measurement, maintenance, 

corrective action, report or record. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be retained 

off site. The files may be maintained on microfilm, on a computer, on floppy 

disks, on magnetic tape, or on microfiche. Requirements of Provision I.S.1 of 

this permit also apply. (origin: 40 CFR 63.1355) 

II.B.1.g.3 Reporting: 

In addition to the requirements in Section I of this permit, one summary report 

shall be submitted semiannually for the hazardous air pollutants monitored at 

each affected source. The summary report shall be entitled "Summary Report - 

Gaseous and Opacity Excess Emission and Continuous Monitoring System 

Performance" and shall contain the following information: 

(A) The company name and address of the affected source; 

(B) An identification of each hazardous air pollutant monitored at the affected 

source; 

(C) The beginning and ending dates of the reporting period; 

(D) A brief description of the process units; 

(E) The emission and operating parameter limitations from 40 CFR 63 Subpart 

LLL; 

(F) The monitoring equipment manufacturer(s) and model number(s); 

(G) All exceedances of maximum control device inlet gas temperature limits; 

(H) All failures to calibrate thermocouples and other temperature sensors as 

required, 

(I) All failures to maintain the activated carbon injection rate, and the activated 

carbon injection carrier gas flow rate or pressure drop, as applicable; 

(J) The results of any combustion system component inspections conducted 

within the reporting period; 

(K) All failures to comply with any provision of the operation and maintenance 

plan; 

(L) The date of the latest CMS certification or audit; 

(M) The total operating time of the affected source during the reporting period; 

(N) An emission data summary (or similar summary if the owner or operator 

monitors control system parameters), including the total duration of excess 

emissions during the reporting period (recorded in minutes for opacity and hours 

for gases), the total duration of excess emissions expressed as a percent of the 

total source operating time during that reporting period, and a breakdown of the 

total duration of excess emissions during the reporting period into those that are 

Issued December 1, 2006 Page 14 Title V Operating Permit #2300015002 
due to startup/shutdown, control equipment problems, process problems, other 

known causes, and other unknown causes; 

(O) A CMS performance summary (or similar summary if the owner or operator 

monitors control system parameters), including the total CMS downtime during 

the reporting period (recorded in minutes for opacity and hours for gases), the 

total duration of CMS downtime expressed as a percent of the total source 

operating time during that reporting period, and a breakdown of the total CMS 

downtime during the reporting period into periods that are due to monitoring 

equipment malfunctions, nonmonitoring equipment malfunctions, quality 

assurance/quality control calibrations, other known causes, and other unknown 

causes; 

(P) A description of any changes in CMS, processes, or controls since the last 

reporting period; 

(Q) The name, title, and signature of the responsible official who is certifying the 

accuracy of the report; and 

(R) The date of the report. 

The owner or operator shall submit all reports to the Executive Secretary as well 

as a copy of each report to the EPA Regional office at: 

EPA Region VIII 

Director 

Air and Toxics Division 

999 18th St. 

1 Denver Place, Suite 300 

Denver, CO 80202-2405 

The regional office may waive this requirement for any reports at its discretion. 

(origin: 40 CFR 63.10(e)(3)(vi) via 40 CFR 63.1354(b)(9)) 

II.B.1.h Condition: 

For all emission units subject to 40 CFR 63 Subpart LLL: 

(i) The permittee must implement a written startup, shutdown, and malfunction plan that 

describes, in detail, procedures for operating and maintaining the affected emission unit 

during periods of startup, shutdown, and malfunction, and a program of corrective action 

for malfunctioning process and air pollution control and monitoring equipment used to 

comply with the relevant standard. [40 CFR 63.6(e)(3)(i)] 

(ii) During periods of startup, shutdown, and malfunction, the permittee must operate and 

maintain the affected emission unit (including associated air pollution control and 

monitoring equipment) in accordance with the procedures specified in the startup, 

shutdown, and malfunction plan developed under paragraph (i) of this condition. [40 CFR 

63.6(3)(3)(ii)] 

(iii) The permittee must maintain a current startup, shutdown, and malfunction plan and 

must make the plan available upon request for inspection and copying by the Executive 

Secretary. In addition, if the startup, shutdown, and malfunction plan is subsequently 

revised as provided in paragraph (v) of this condition, the permittee must maintain each 

previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, and 

must make each such previous version available for inspection and copying by the 

Issued December 1, 2006 Page 15 Title V Operating Permit #2300015002 
Executive Secretary for a period of 5 years after revision of the plan. If at any time after 

adoption of a startup, shutdown, and malfunction plan the affected emission unit ceases 

operation or is otherwise no longer subject to the provisions of 40 CFR 63, the permittee 

must retain a copy of the most recent plan for 5 years from the date the affected emission 

unit ceases operation or is no longer subject to 40 CFR 63 and must make the plan 

available upon request for inspection and copying by the Executive Secretary. [40 CFR 

63.6(e)(3)(v)] 

(iv) To satisfy the requirements of this condition to develop a startup, shutdown, and 

malfunction plan, the permittee may use the affected emission unit's standard operating 

procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) 

or other plan, provided the alternative plans meet all the requirements of this condition 

and are made available for inspection when requested by the Executive Secretary. [40 

CFR 63.6(e)(3)(vi)] 

(v) The permittee may periodically revise the startup, shutdown, and malfunction plan as 

necessary to satisfy the requirements of 40 CFR 63 or to reflect changes in equipment or 

procedures at the affected emission unit. However, each such revision to a startup, 

shutdown, and malfunction plan must be reported in the semiannual report required by 

this permit. If the startup, shutdown, and malfunction plan fails to address or inadequately 

addresses an event that meets the characteristics of a malfunction but was not included in 

the startup, shutdown, and malfunction plan at the time the permittee developed the plan, 

the permittee must revise the startup, shutdown, and malfunction plan within 45 days 

after the event to include detailed procedures for operating and maintaining the affected 

emission unit during similar malfunction events and a program of corrective action for 

similar malfunctions of process or air pollution control and monitoring equipment. In the 

event that the permittee makes any revision to the startup, shutdown, and malfunction 

plan which alters the scope of the activities at the affected emission unit which are 

deemed to be a startup, shutdown, or malfunction, or otherwise modifies the applicability 

of any emission limit, work practice requirement, or other requirement in a standard 

established under 40 CFR 63, the revised plan shall not take effect until after the 

permittee has provided a written notice describing the revision to the permitting 

authority. [40 CFR 63.6(e)(3)(viii)] 

(vi) Any revisions made to the startup, shutdown, and malfunction plan in accordance 

with the procedures established by 40 CFR 63 shall not be deemed to constitute permit 

revisions under this permit. Moreover, none of the procedures specified by the startup, 

shutdown, and malfunction plan shall be deemed to fall within the permit shield provision 

in this permit. [40 CFR 63.6(e)(3)(ix)] [Authority granted under 40 CFR 63 Subpart A, 

LLL; condition originated in 40 CFR 63 (Subpart LLL)] 

II.B.1.h.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.1.h.2 Recordkeeping: 

The permittee shall maintain relevant records for the affected emission unit of— 

(i) The occurrence and duration of each startup, shutdown, or malfunction of 

operation (i.e., process equipment); [40 CFR 63.10(b)(2)(i)] 

Issued December 1, 2006 Page 16 Title V Operating Permit #2300015002 
(ii) The occurrence and duration of each malfunction of the required air pollution 

control and monitoring equipment; [40 CFR 63.10(b)(2)(ii)] 

(iii) All required maintenance performed on the air pollution control and 

monitoring equipment; [40 CFR 63.10(b)(2)(iii)] 

(iv) Actions taken during periods of startup, shutdown, and malfunction 

(including corrective actions to restore malfunctioning process and air pollution 

control and monitoring equipment to its normal or usual manner of operation) 

when such actions are different from the procedures specified in the startup, 

shutdown, and malfunction plan; [40 CFR 63.10(b)(2)(iv)] 

(v) All information necessary to demonstrate conformance with the startup, 

shutdown, and malfunction plan when all actions taken during periods of startup, 

shutdown, and malfunction (including corrective actions to restore 

malfunctioning process and air pollution control and monitoring equipment to its 

normal or usual manner of operation) are consistent with the procedures specified 

in such plan. These records may take the form of a "checklist," or other effective 

form of recordkeeping that confirms conformance with the startup, shutdown, 

and malfunction plan for that event. [40 CFR 63.6(e)(3)(iii) & 40 CFR 

63.10(b)(2)(v)] 

(vi) If an action taken by the permittee during a startup, shutdown, or 

malfunction (including an action taken to correct a malfunction) is not consistent 

with the procedures specified in the startup, shutdown, and malfunction plan, and 

the affected emission unit exceeds any applicable emission limitation in the 

relevant emission standard, then the permittee must record the actions taken for 

that event. [40 CFR 63.6(e)(3)(iv)] 

The permittee shall maintain files of all information (including all reports and 

notifications) required by this condition recorded in a form suitable and readily 

available for expeditious inspection and review. The files shall be retained for at 

least five years following the date of each occurrence, measurement, 

maintenance, corrective action, report, or record. At a minimum, the most recent 

two years of data shall be retained on site. The remaining three years of data may 

be retained off site. The files may be maintained on microfilm, on a computer, on 

computer floppy disks, on magnetic tape disks, or on microfiche. [40 CFR 

63.1355(a) & 40 CFR 63.10(b)(1)] 

Requirements of Provision I.S.1 of this permit also apply. 

II.B.1.h.3 Reporting: 

In addition to the reporting requirements specified in Section I of this permit, in 

the event of a startup, shutdown or malfunction, the following reporting 

requirements shall be followed: 

(i) Periodic startup, shutdown, and malfunction reports. If actions taken by the 

permittee during a startup, shutdown, or malfunction (including actions taken to 

correct a malfunction) are consistent with the procedures specified in the startup, 

shutdown, and malfunction plan, the permittee shall state such information in a 

startup, shutdown, and malfunction report. Otherwise, such a report shall identify 

Issued December 1, 2006 Page 17 Title V Operating Permit #2300015002 
any instance where any action taken by a permittee during a startup, shutdown, or 

malfunction (including actions taken to correct a malfunction) is not consistent 

with the startup, shutdown, and malfunction plan, but the affected emission unit 

does not exceed any applicable emission limitation in the relevant emission 

standard. Such a report shall also include the number, duration, and a brief 

description for each type of malfunction which occurred during the reporting 

period and which caused or may have caused any applicable emission limitation 

to be exceeded. Reports shall only be required if a startup, shutdown, or 

malfunction occurred during the reporting period. The startup, shutdown, and 

malfunction report shall consist of a letter, containing the name, title, and 

signature of the responsible official who is certifying its accuracy, that shall be 

submitted to the Executive Secretary semiannually. The startup, shutdown, and 

malfunction report shall be delivered or postmarked by the 30th day following 

the end of each calendar half. The startup, shutdown, and malfunction report may 

be submitted simultaneously with the excess emissions and continuous 

monitoring system performance reports. [40 CFR 63.1354(b)(4) & 40 CFR 

63.10(d)(5)(i) & 40 CFR 63.6(e)(3)(iii)] 

(ii) Immediate startup, shutdown, and malfunction reports. If an action taken by 

the permittee during a startup, shutdown, or malfunction (including actions taken 

to correct a malfunction) is not consistent with the procedures specified in the 

startup, shutdown, and malfunction plan, the permittee shall report the actions 

taken for that event within 2 working days after commencing actions inconsistent 

with the plan followed by a letter within 7 working days after the end of the 

event. The immediate report required under this paragraph shall consist of a 

telephone call or facsimile (FAX) transmission to the Executive Secretary within 

2 working days after commencing actions inconsistent with the plan, and it shall 

be followed by a letter, delivered or postmarked within 7 working days after the 

end of the event, that contains the name, title, and signature of the responsible 

official who is certifying its accuracy, explaining the circumstances of the event, 

the reasons for not following the startup, shutdown, and malfunction plan, and 

describing all excess emissions and/or parameter monitoring exceedances which 

are believed to have occurred. [40 CFR 63.6(e)(3)(iv) & 40 CFR 63.10(d)(5)(ii) 

& 40 CFR 63.1354(b)(5)] 

II.B.1.i Condition: 

Visible emissions shall be no greater than 10 percent opacity from the baghouses unless 

otherwise specified in this permit. [Authority granted under R307-401-8(1)(a) [BACT]; 

condition originated in DAQE-AN0303012-06] 

II.B.1.i.1 Monitoring: 

(a) The permittee shall conduct a monthly 1-minute visible emissions test of 

each affected source in accordance with 40 CFR 60, Appendix A, Method 

22. The test must be conducted while the affected source is in operation. 

(b) If no visible emissions are observed in six consecutive monthly tests for any 

affected source, the permittee may decrease the frequency of testing from 

monthly to semi-annually for that affected source. If visible emissions are 

observed during any semi-annual test, the permittee must resume testing of 

that affected source on a monthly basis and maintain that schedule until no 

visible emissions are observed in six consecutive monthly tests. 

Issued December 1, 2006 Page 18 Title V Operating Permit #2300015002 
(c) If no visible emissions are observed during the semi-annual test for any 

affected source, the permittee may decrease the frequency of testing from 

semi-annually to annually for that affected source. If visible emissions are 

observed during any annual test, the permittee shall resume testing of that 

affected source on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. 

(d) If visible emissions are observed during any Method 22 test, the permittee 

shall conduct a 6-minute test of opacity in accordance with 40 CFR 60, 

Appendix A, Method 9. The Method 9 test must begin within one hour of 

any observation of visible emissions. 

II.B.1.i.2 Recordkeeping: 

Records of visual observations performed and data required by 40 CFR 60, 

Appendix A, Method 9 for each determination shall be maintained in accordance 

with Provision I.S.1 of this permit. 

II.B.1.i.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.1.j Condition: 

In accordance with Provision I.L.1 of this permit, the permittee shall submit to the 

Executive Secretary an annual compliance certification, certifying compliance with the 

terms and conditions contained in this permit, including emission limitations, standards, 

or work practices no later than December 15, 2006. [Authority granted under R307-415-

6c; condition originated in R307-415-6c] 

II.B.1.j.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.1.j.2 Recordkeeping: 

A copy of the compliance certification required by this condition shall be 

retained for a period of at least five years and in accordance with Section I of this 

permit. 

II.B.1.j.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I.L and Section I.S of this permit. 

II.B.2 Conditions on Stationary Crusher (211.BF1)

II.B.2.a Condition: 

Permittee shall operate water sprays or dust suppression sprays to control fugitive 

emissions. The sprays shall operate whenever dry conditions warrant or as determined 

necessary by the Executive Secretary. Sprays shall not be required during periods of 

freezing temperatures. [Authority granted under R307-401-8(1)(a) [BACT]; condition 

originated in DAQE-AN0303012-06] 

II.B.2.a.1 Monitoring: 

Visual inspections of the water spray system(s) shall be made weekly to ensure 

proper operating condition. 

Issued December 1, 2006 Page 19 Title V Operating Permit #2300015002 
II.B.2.a.2 Recordkeeping: 

An operator’s log shall be maintained of all monitoring provisions listed above. 

Records of water spray system inspections shall be kept for all periods of 

operation and the ambient temperature shall be recorded any time water should 

be applied but can not be due to freezing conditions. 

II.B.2.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.2.b Condition: 

Visible emissions shall be no greater than 10 percent opacity from the baghouse. 

[Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06] 

II.B.2.b.1 Monitoring: 

Compliance with the visible emission limitation shall be demonstrated by one of 

the following options. 

Option A: 

(I) Measurement Approach: The permittee shall monitor opacity by conducting 

daily visual emissions observations in accordance with the procedures of 40 

CFR 60, Appendix A, Method 22. 

(II) Indicator Range: An excursion is defined as the presence of visible 

emissions. If visible emissions are observed during any Method 22 visible 

emissions test, the permittee shall: 

a) Initiate corrective actions, within one-hour; and 

b) Within 24 hours of the end of the Method 22 test in which visible 

emissions were observed, conduct a followup Method 22 test of each 

stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are observed during the followup 

Method 22 test from any stack from which visible emissions were 

observed during the previous Method 22 test, conduct a visual opacity 

test of each stack from which emissions were observed during the follow 

up Method 22 test in accordance with 40 CFR 60, Appendix A, Method 

9. The duration of the Method 9 test shall be 30 minutes. 

(III) Performance Criteria: 

a) Data Representativeness: The Method 22 test shall be conducted while 

the affected unit is operating at representative performance conditions. 

b) QA/QC Practices and Criteria: The visual observer shall be familiar with 

40 CFR, Appendix A, Method 22 and follow Method 22 procedures. The 

opacity determination shall be conducted by a certified VEO in 

accordance with 40 CFR 60, Appendix A, Method 9. 

c) Monitoring Frequency: A Method 22 observation shall be performed 

daily for each affected unit. The duration of the Method 22 test shall be 6 

minutes. 

d) Data Collection Procedure: The observation shall be documented by the 

observer and all data required by 40 CFR 60, Appendix A, Method 9 

shall be maintained if the opacity determination is conducted. 

e) Averaging Period: None 

Issued December 1, 2006 Page 20 Title V Operating Permit #2300015002 
Option B: 

(I) Measurement Approach: A BLDS shall be installed on the baghouse exhaust 

stack and generate a signal proportional to PM concentration. An alarm shall 

sound when the signal exceeds a preset limit. 

(II) Indicator Range: An excursion is defined as a signal greater than or equal to 

50% of scale during normal operating conditions. Excursions trigger an 

inspection, corrective action, and a reporting requirement. 

The permittee shall maintain and operate the fabric filter such that the bag 

leak detector alarm is not activated and alarm condition does not exist for 

more than 5 percent of the total operating time in a 6-month block period. 

Each time the alarm activates, alarm time shall be counted as the actual 

amount of time taken by the permittee to initiate corrective actions. If 

inspection of the fabric filter demonstrates that no corrective actions are 

necessary, no alarm time shall be counted. 

(III) Performance Criteria: 

a. Data Representativeness: 

1) For a positive-pressure fabric filter, the bag leak detector shall be 

installed in the exit vent. For a negative-pressure or induced-air 

fabric filter, the bag leak detector shall be installed downstream of 

the fabric filter. If multiple bag leak detectors are required (for either 

type of fabric filter), detectors may share the system instrumentation 

and alarm. 

2) The baseline output of the system shall be established as follows: 

a) Adjust the range and the averaging period of the device; and 

b) Establish the alarm set points and the alarm delay time. 

3) The sensor on the BLDS shall provide output of relative PM 

emissions. 

4) The BLDS shall have an alarm that will activate automatically when 

it detects PM emissions greater than or equal to 50% of scale during 

normal operating conditions. 

5) The presence of an alarm condition shall be clearly apparent to 

facility operating personnel. 

b. QA/QC Practices and Criteria: 

1) The probe shall be inspected at least monthly for dust buildup. 

2) Lens cleaning, O-ring replacement, and window value rechecks shall 

be performed at least annually. 

3) The BLDS shall be certified by the manufacturer to be capable of 

detecting PM emissions at concentrations of 10 milligrams per actual 

cubic meter (0.0044 grains per actual cubic foot) or less. "Certify" 

shall mean that the instrument manufacturer has tested the instrument 

on gas streams having a range of particle size distributions and 

confirmed by means of valid filterable PM tests that the minimum 

detectable concentration limit is at or below 10 milligrams per actual 

cubic meter (0.0044 grains per actual cubic foot) or less. 

4) All BLDS shall be installed, operated, adjusted, and maintained so 

that they are based on the manufacturer's written specifications and 

recommendations. 

5) After initial adjustment, the range, averaging period, alarm set 

points, or alarm delay time shall not be adjusted except as specified 

in the BLDS standard operating procedure (SOP). In no event shall 

Issued December 1, 2006 Page 21 Title V Operating Permit #2300015002 
the range be increased by more than 100 percent or decreased by 

more than 50 percent over a 1 calendar year period unless a 

responsible official as defined in R307-415-3 certifies in writing to 

the executive secretary that the fabric filter has been inspected and 

found to be in good operating condition. 

c. Monitoring Frequency: The BLDS signal shall be monitored 

continuously. 

d. Data Collection Procedure: The instantaneous values from the 

transmitter output shall be displayed and recorded. All alarms shall be 

logged electronically. 

e. Averaging Period: None. 

II.B.2.b.2 Recordkeeping: 

The following records shall be maintained in accordance with Provision I.S.1 of 

this permit: 

(a) The permittee shall continuously record the output from the BLDS during 

periods of normal operation. Normal operation does not include periods 

when the BLDS is being maintained or during startup, shutdown or 

malfunction. 

(b) Alarm times as defined in Monitoring shall be recorded. 

(c) Records of visual emission observations and visual opacity tests required by 

40 CFR 60, Appendix A, Methods 22 and 9 shall be maintained if a BLDS is 

not used. 

In addition to the recordkeeping requirements described in Provision I.S.1 of this 

permit, the permittee shall maintain a file of the occurrence and duration of any 

excursion, corrective actions taken, and any other supporting information 

required to be maintained under 40 CFR 64 (such as data used to document the 

adequacy of monitoring, or records of monitoring maintenance or corrective 

actions). Instead of paper records, the permittee may maintain records on 

alternative media, such as microfilm, computer files, magnetic tape disks, or 

microfiche, provided that the use of such alternative media allows for expeditious 

inspection and review, and does not conflict with other applicable recordkeeping 

requirements. (40 CFR 64.9(b)) 

II.B.2.b.3 Reporting: 

In addition to the reporting requirement described in Provision I.S.2 of this 

permit, the monitoring report shall include, at a minimum, the following 

information, as applicable: 

(i) Summary information on the number, duration and cause (including 

unknown cause, if applicable) of excursions or exceedances, as applicable, 

and the corrective actions taken; (40 CFR 64.9(a)(2)(i)) 

(ii) Summary information on the number, duration and cause (including 

unknown cause, if applicable) for monitor downtime incidents (other than 

downtime associated with zero and span or other daily calibration checks, if 

applicable). (40 CFR 64.9(a)(2)(ii)) 

Issued December 1, 2006 Page 22 Title V Operating Permit #2300015002 
II.B.3 Conditions on Raw Material Transfer (211.BF2)

II.B.3.a Condition: 

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 

R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06] 

II.B.3.a.1 Monitoring: 

(a) The permittee shall conduct a monthly 1-minute visible emissions test of 

each affected source in accordance with 40 CFR 60, Appendix A, Method 

22. The test must be conducted while the affected source is in operation. 

(b) If no visible emissions are observed in six consecutive monthly tests for any 

affected source, the permittee may decrease the frequency of testing from 

monthly to semi-annually for that affected source. If visible emissions are 

observed during any semi-annual test, the permittee must resume testing of 

that affected source on a monthly basis and maintain that schedule until no 

visible emissions are observed in six consecutive monthly tests. 

(c) If no visible emissions are observed during the semi-annual test for any 

affected source, the permittee may decrease the frequency of testing from 

semiannually to annually for that affected source. If visible emissions are 

observed during any annual test, the permittee shall resume testing of that 

affected source on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. 

(d) If visible emissions are observed during any Method 22 test, the permittee 

shall conduct a six minute test of opacity in accordance with 40 CFR 60, 

Appendix A, Method 9. The Method 9 test must begin within one hour of 

any observation of visible emissions. 

II.B.3.a.2 Recordkeeping: 

Records of visible emission tests performed and data required by 40 CFR 60, 

Appendix A, Method 22 and 9 shall be maintained in accordance with Provision 

I.S.1 of this permit. 

II.B.3.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.3.b Condition: 

Permittee shall operate water sprays or dust suppression sprays to control fugitive 

emissions. The sprays shall operate whenever dry conditions warrant or as determined 

necessary by the Executive Secretary. Sprays shall not be required during periods of 

freezing temperatures. [Authority granted under R307-401-8(1)(a) [BACT]; condition 

originated in DAQE-AN0303012-06] 

II.B.3.b.1 Monitoring: 

Visual inspections of the water spray system(s) shall be made weekly to ensure 

proper operating condition. 

II.B.3.b.2 Recordkeeping: 

An operator’s log shall be maintained of all monitoring provisions listed above. 

Records of water spray system inspections shall be kept for all periods of 

Issued December 1, 2006 Page 23 Title V Operating Permit #2300015002 
operation and the ambient temperature shall be recorded any time water should 

be applied but can not be due to freezing conditions. 

II.B.3.b.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.4 Conditions on Coal Grinding System (41B.BF2)

II.B.4.a Condition: 

Visible emissions shall be less than 20 percent opacity. [Authority granted under 40 CFR 

60.252(a),(c) (Subpart Y); condition originated in 40 CFR 60 (Subpart Y)] 

II.B.4.a.1 Monitoring: 

A visual observation of each affected emission unit shall be performed on a 

weekly basis by an individual trained on the observation procedures of 40 CFR 

60, Appendix A, Method 9. The individual is not required to be a certified 

visible emissions observer (VEO). If any visible emissions are observed, an 

opacity determination of that emission unit shall be performed by a certified 

VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of 

the initial observation. For each affected emission unit, if no visible emissions 

are observed for eight consecutive weeks the observation frequency shall be 

reduced to a monthly basis. If visible emissions are observed during any monthly 

observation the frequency shall revert back to a weekly basis. 

II.B.4.a.2 Recordkeeping: 

Records of visual observations performed and data required by 40 CFR 60, 

Appendix A, Method 9 for each determination shall be maintained in accordance 

with Provision I.S.1 of this permit. 

II.B.4.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.4.b Condition: 

During all periods of operation, the permittee shall record the operating temperature of 

the Coal Grinding System baghouse. [Authority granted under 40 CFR 63.8(f); condition 

originated in Alternative Monitoring EPA Approval 11/6/02] 

II.B.4.b.1 Monitoring: 

The permittee shall install and operate a temperature alarm on the baghouse inlet 

in accordance with the manufacturer’s specifications. (origin: Alternative 

Monitoring EPA Approval 11/6/02) 

II.B.4.b.2 Recordkeeping: 

Records required by this permit condition and copies of the manufacturer’s alarm 

specifications shall be maintained in accordance with Provision I.S.1 of this 

permit and made available for review by the Executive Secretary or his 

representative. (origin: Alternative Monitoring EPA Approval 11/6/02) 

Issued December 1, 2006 Page 24 Title V Operating Permit #2300015002 
II.B.4.b.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.4.c Condition: 

The permittee shall not cause to be discharged into the atmosphere from any thermal 

dryer gases which contain particulate matter in excess of 0.070 g/dscm (0.031 gr/dscf). 

[Authority granted under 40 CFR 60.252(a) (Subpart Y); condition originated in 40 CFR 

60 (Subpart Y)] 

II.B.4.c.1 Monitoring: 

Stack testing shall be performed as specified below: 

(a) Testing and Frequency. Emissions shall be tested every five years, based on 

the date of the most recent stack test. Tests may also be required at the direction 

of the Executive Secretary. 

(b) Notification. At least 30 days before the test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy of 

the test protocol. The source shall attend a pretest conference if determined 

necessary by the Executive Secretary. 

(c) Methods. 

 (1) Sample Location - the emission point shall conform to the 

requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety 

and Health Administration (OSHA) and/or Mine Safety and Health 

Administration (MSHA)-approved access shall be provided to the test location. 

 (2) Sample Method - 40 CFR 60. Appendix A, Method 5 shall be used 

to determine the particulate matter concentration and the volumetric flow rate of 

the effluent gas. The sampling time and sample volume shall be at least 60 

minutes and 0.85 dscm (30 dscf). Sampling shall begin no less than 30 minutes 

after startup and shall terminate before shutdown procedures begin. 

(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant 

concentration as determined by the appropriate methods above shall be 

multiplied by the volumetric flow rate and any necessary conversion factors 

determined by the Executive Secretary to give the results in the specified units of 

the emission limitation. 

(e) Production Rate During Testing. The production rate during all compliance 

testing shall be no less than 90% of the maximum production achieved in the 

previous three (3) years. 

In addition to the stack testing requirements, the permittee shall install, calibrate, 

maintain, and continuously operate a monitoring device for the measurement of 

the temperature of the gas stream at the exit of the thermal dryer on a continuous 

basis. The monitoring device shall be certified by the manufacturer to be 

accurate within +/- 1.7 degrees Celsius (+/- 3 degrees Fahrenheit). The 

Issued December 1, 2006 Page 25 Title V Operating Permit #2300015002 
monitoring device shall be recalibrated annually in accordance with the 

manufacturer's written requirements or recommendations. 

II.B.4.c.2 Recordkeeping: 

Results of monitoring shall be maintained in accordance with Provision I.S.1 of 

this permit. In addition, results of all stack testing shall be recorded and 

maintained in accordance with the associated test method. 

II.B.4.c.3 Reporting: 

The results of stack testing shall be submitted to the Executive Secretary within 

60 days of completion of the testing. Reports shall clearly identify results as 

compared to permit limits and indicate compliance status. There are no 

additional reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.5 Conditions on Coal Silo (41B.BF1)

II.B.5.a Condition: 

Visible emissions shall be less than 20 percent opacity. [Authority granted under 40 CFR 

60.252(c) (Subpart Y); condition originated in 40 CFR 60 (Subpart Y) & DAQEAN0303012-06] 

II.B.5.a.1 Monitoring: 

A visual observation of each affected emission unit shall be performed on a 

weekly basis by an individual trained on the observation procedures of 40 CFR 

60, Appendix A, Method 9. The individual is not required to be a certified 

visible emissions observer (VEO). If any visible emissions are observed, an 

opacity determination of that emission unit shall be performed by a certified 

VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of 

the initial observation. For each affected emission unit, if no visible emissions 

are observed for eight consecutive weeks the observation frequency shall be 

reduced to a monthly basis. If visible emissions are observed during any monthly 

observation the frequency shall revert back to a weekly basis. 

II.B.5.a.2 Recordkeeping: 

Records of visual observations performed and data required by 40 CFR 60, 

Appendix A, Method 9 for each determination shall be maintained in accordance 

with Provision I.S.1 of this permit. 

II.B.5.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6 Conditions on Kiln & Pre-Calciner and Raw Mill (317.BF1)

II.B.6.a Condition: 

Emissions of particulate matter shall be no greater than 0.30 lbs per ton (0.15 kg/Mg) of 

kiln feed (dry basis). [Authority granted under R307-401-8(1)(a) [BACT] & 40 CFR 63 

(Subpart LLL); condition originated in DAQE-AN0303012-06 & 40 CFR 63 (Subpart 

LLL)] 

Issued December 1, 2006 Page 26 Title V Operating Permit #2300015002 
II.B.6.a.1 Monitoring: 

Stack testing shall be performed as specified below: 

(a) Frequency. Emissions shall be tested every five (5) years, based on the date 

of the most recent stack test. Tests may also be required at the direction of the 

Executive Secretary. 

(b) Notification. At least 60 days before the test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy of 

the test protocol. The source shall attend a pretest conference if determined 

necessary by the Executive Secretary. 

(c) Methods. 

 (1) Sample Location - the emission point shall conform to the 

requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety 

and Health Administration (OSHA) or Mine Safety and Health Administration 

(MSHA) approvable access shall be provided to the test location. 

 (2) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used 

to determine particulate matter emissions and the volumetric flow rate of the 

effluent gas. Each test shall consist of three separate runs. Each run shall be 

conducted for at least one hour, and the minimum sample volume shall be 0.85 

dscm (30 dscf). The average of the three runs shall be used to determine 

compliance. The emission rate of particulate matter shall be computed for each 

run using the equation in 40 CFR 63.1349(b)(1). 

(d) Production Rate During Testing. The production rate during all compliance 

testing shall be no less than 90% of the maximum production achieved in the 

previous three (3) years. 

II.B.6.a.2 Recordkeeping: 

Results of all stack testing shall be recorded and maintained in accordance with 

the associated test method and Provision S.1 in Section I of this permit. 

II.B.6.a.3 Reporting: 

The results of stack testing shall be submitted to the Executive Secretary within 

60 days of completion of the testing. Reports shall clearly identify results as 

compared to permit limits and indicate compliance status. There are no 

additional reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.b Condition: 

Emissions of PM10 shall be no greater than 20.5 lbs/hr. [Authority granted under R307-

401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06] 

II.B.6.b.1 Monitoring: 

(a) Stack testing shall be performed as specified below: 

(i) Frequency. Emissions shall be tested every three years. Tests may also 

be required at the direction of the Executive Secretary. 

Issued December 1, 2006 Page 27 Title V Operating Permit #2300015002 
(ii) Notification. At least 30 days before the test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy 

of the test protocol. The source shall attend a pretest conference if 

determined necessary by the Executive Secretary. 

(iii) Methods. 

a. Sample Location - the emission point shall conform to the 

requirements of 40 CFR 60, Appendix A, Method 1, and Occupational 

Safety and Health Administration (OSHA) and/or Mine Safety and 

Health Administration (MSHA) approved access shall be provided to the 

test location. 

b. For stacks in which no liquid drops are present, the following 

methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. 

Method 202 may be used to measure condensible particulate matter. 

c. For stacks in which liquid drops are present, methods to eliminate 

the liquid drops should be explored. If no reasonable method to eliminate 

the drops exists, then the following methods shall be used: 40 CFR 60, 

Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half 

condensibles shall also be tested using a method specified by the 

Executive Secretary. All particulate captured shall be considered PM10. 

d. The back half condensibles shall not be used for compliance 

demonstration but shall be used for inventory purposes. 

(iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant 

concentration as determined by the appropriate methods above shall be 

multiplied by the volumetric flow rate and any necessary conversion factors 

determined by the Executive Secretary to give the results in the specified 

units of the emission limitation. 

(v) Production Rate During Testing. The production rate during all 

compliance testing shall be no less than 90% of the maximum production 

achieved in the previous three (3) years. 

(b) Optical density shall be used as an indicator to provide reasonable assurance 

of compliance with the PM10 emission limitation as specified below. 

(i) Measurement Approach: Opacity shall be determined using a continuous 

opacity monitor (COM) located in the exhaust stack. The opacity shall 

be mathematically converted to units of optical density. 

(ii) Indicator Range: An excursion is defined as a 24-hour block average 

optical density in excess of 0.041 excluding periods of startup, shutdown, 

or malfunction. Excursions trigger an inspection, corrective action, and a 

reporting requirement. 

Once every three years, during the stack test required in (a) above, the 

permittee shall acquire new test data to evaluate or update the excursion 

optical density value. The procedure for collecting new test data is 

described in a reviewer comment at the end of this permit. 

(iii) Performance Criteria: 

a. Data Representativeness: The COM shall be installed in a 

representative location in the exhaust stack and shall be calibrated, 

maintained, and operated in accordance with 40 CFR Part 60 

Appendix B Performance Specification 1 and R307-170. 

b. QA/QC Practices and Criteria: The COM shall be calibrated, 

maintained, and operated in accordance with 40 CFR Part 60 

Appendix B Performance Specification 1, R307-170, and the 

manufacturer’s written recommendations. 

Issued December 1, 2006 Page 28 Title V Operating Permit #2300015002 
c. Monitoring Frequency: Opacity shall be monitored continuously and 

a data point recorded electronically every 10 seconds. 

d. Data Collection Procedure: The 10-second opacity data shall be 

used to calculate 6-minute opacity averages. The 6-minute opacity 

averages shall be mathematically converted to units of optical 

density. The 6-minute optical density values shall be averaged over 

a 1-hour block. The 1-hour optical density averages shall be used to 

calculate a 24-hour block average. The 24-hour block average 

optical density shall be recorded and stored electronically. 

e. Averaging Period: 24-hour block average. 

II.B.6.b.2 Recordkeeping: 

Results of all stack testing shall be recorded and maintained in accordance with 

the associated test method and Provision I.S.1 of this permit. 

Records of the 24-hour block average optical density values shall be maintained 

in accordance with Provision I.S.1 of this permit. In addition, the permittee shall 

maintain records of: 

a) all test data from the most recent stack test and the calculations that were 

used to evaluate or revise the excursion optical density value. 

b) all continuous opacity monitor (COM) parameters, performance test 

measurements, all COM performance evaluations, all COM calibration 

checks, all COM adjustments and maintenance, and all other information 

required by R307-170 in a permanent form suitable for inspection. 

c) the occurrence and duration of any excursion, corrective actions taken, and 

any other supporting information required to be maintained under 40 CFR 64 

(such as data used to document the adequacy of monitoring, or records of 

monitoring maintenance or corrective actions). Instead of paper records, the 

permittee may maintain records on alternative media, such as microfilm, 

computer files, magnetic tape disks, or microfiche, provided that the use of 

such alternative media allows for expeditious inspection and review, and 

does not conflict with other applicable recordkeeping requirements. (40 CFR 

64.9(b)) 

II.B.6.b.3 Reporting: 

In addition to the reporting requirements in Provision I.S.2 of this permit, 

(a) Monitoring reports shall include, at a minimum, the following information, 

as applicable: 

(i) Summary information on the number, duration and cause (including 

unknown cause, if applicable) of excursions or exceedances, as 

applicable, and the corrective actions taken; (40 CFR 64.9(a)(2)(i)) 

(ii) Summary information on the number, duration and cause (including 

unknown cause, if applicable) for monitor downtime incidents (other 

than downtime associated with zero and span or other daily calibration 

checks, if applicable). (40 CFR 64.9(a)(2)(ii)) 

(b) The results of stack testing shall be submitted to the Executive Secretary 

within 60 days of completion of the testing. Reports shall clearly identify 

results as compared to permit limits and indicate compliance status. 

Issued December 1, 2006 Page 29 Title V Operating Permit #2300015002 
II.B.6.c Condition: 

Visible emissions shall be no greater than 20 percent opacity. [Authority granted under 

40 CFR 63, Subpart LLL; condition originated in DAQE-AN0303012-06] 

II.B.6.c.1 Monitoring: 

The permittee shall calibrate, maintain and operate a continuous monitoring 

system for measuring the opacity of emissions discharged to the atmosphere in 

accordance with R307-170 and 40 CFR 63.8 (Subpart A), and shall record the 

output of the system. The output shall be reviewed at least monthly for 

compliance with the opacity limit; compliance is to be based on the percent 

opacity averaged over six consecutive minutes. 

II.B.6.c.2 Recordkeeping: 

Results of opacity observations shall be recorded and maintained as required in 

R307-170 and as described in Provision I.S.1 of this permit. 

II.B.6.c.3 Reporting: 

The permittee shall comply with the reporting provisions in R307-170-9 and any 

additional reporting provisions contained in Section I of this permit. 

The quarterly reports required in R307-170-9 are considered prompt notification 

of permit deviations required in Provision I.S.2.c of this permit if all information 

required by Provision I.S.2.c is included in the report. 

II.B.6.d Condition: 

Emissions of NOx shall be no greater than 2,165 tons per rolling 12-month period. 

[Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06] 

II.B.6.d.1 Monitoring: 

While the affected emission unit is operating, hourly NOx emission rates 

expressed in tons per hour shall be determined in accordance with R307-170 

using the appropriate conversion factors. The applicable performance 

specification in R307-170 shall be 40 CFR 60, Appendix B, Performance 

Specification 6 - "Specifications and Test Procedures for Continuous Emission 

Rate Monitoring Systems in Stationary Sources". By the 25th day of each month 

a new 12-month NOx emission total for the common stack shall be calculated as 

the sum of the monthly NOx emission totals for each of the previous 12 months. 

II.B.6.d.2 Recordkeeping: 

The permittee shall keep the records specified in R307-170-8 and any additional 

records required by provision I.S.1 of this permit. These records shall be 

maintained in accordance with Provision I.S.1. 

II.B.6.d.3 Reporting: 

The permittee shall comply with the reporting provisions in R307-170-9 and any 

additional reporting provisions contained in Section I of this permit. 

The quarterly reports required in R307-170-9 are considered prompt notification 

of permit deviations required in Provision I.S.2.c of this permit if all information 

required by Provision I.S.2.c is included in the report. 

Issued December 1, 2006 Page 30 Title V Operating Permit #2300015002 
II.B.6.e Condition: 

The permittee shall use only the following fuels in the kiln and pre-calciner: 

 A. Coal 

 B. Diaper Derived Fuel (DDF) 

 C. Tire Derived Fuel (TDF) 

 D. Natural Gas 

 E. Coke 

 F. Fuel Oil 

 G. Used Oil Fuel 

 H. Synthetic Fuel 

 I. Wood 

 J. Coal Additives consisting of alternative fuels approved by the Executive 

Secretary. Prior to burning any proposed coal additive, the permittee shall obtain 

approval from the Executive Secretary. To obtain approval, the permittee shall submit 

Material Safety Data Sheets (MSDS) or the results of suitable tests giving data similar to 

a Proximate and Ultimate analysis of the proposed coal additive. 

 Approval by the Executive Secretary shall consist of a letter approving 

the use of the proposed coal additive. Approval is not required to change from one 

previously approved coal additive to another previously approved coal additive. 

 The average quantity of coal additives burned shall not be greater than 

15% of the total daily heat input of the kiln and precalciner. The permittee may increase 

the average quantity of coal additives up to 25% of the total daily heat input of the kiln 

and precalciner upon approval by the Executive Secretary in accordance with the 

approval process described for new coal additives above. 

Additionally, the permittee shall be limited to a maximum TDF consumption not to 

exceed 15% of the combined energy input to the rotary kiln and pre-calciner on a 

monthly basis. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated 

in DAQE-AN0303012-06] 

II.B.6.e.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.6.e.2 Recordkeeping: 

Within the first 25 days of each month, a rolling 12-month total of fuel usage 

shall be determined using records from the previous 12 months. The fuel usage 

records shall include the type, quantity, and respective heating value for each 

material used as fuel. Copies of Executive Secretary approval of each coal 

additive shall be maintained. Records shall be maintained in accordance with 

Provision I.S.1 of this permit. 

II.B.6.e.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

Issued December 1, 2006 Page 31 Title V Operating Permit #2300015002 
II.B.6.f Condition: 

Consumption of used oil fuel shall be no greater than 85,724 gallons per rolling 12-month 

period. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in 

DAQE-AN0303012-06] 

II.B.6.f.1 Monitoring: 

Consumption shall be determined within the first 25 calendar days of each 

month, for the previous month, using purchase records and inventory 

information. The total shall then be added to the previous 11 months total for a 

12 month rolling total. 

II.B.6.f.2 Recordkeeping: 

Records of used oil combusted shall be kept daily in a supervisor log for all 

periods when the plant is in operation. Records shall be kept in accordance with 

Provision I.S.1 of this permit. 

II.B.6.f.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.g Condition: 

Permittee shall meet the following requirements when used oil or tire derived fuel (TDF) 

is burned in the rotary kiln: 

 Combustion gas temperature at the rotary kiln exit shall not drop below 1500 degrees 

Fahrenheit for more than five minutes in any 60-minute period. 

 Oxygen content at the kiln system ID fan shall not drop below 2% for more than five 

minutes in any 60-minute period. [Authority granted under R307-401-8(1)(a) [BACT]; 

condition originated in DAQE-AN0303012-06] 

II.B.6.g.1 Monitoring: 

The permittee shall continuously monitor the temperature and oxygen content at 

all times used oil or TDF is burned in the kiln using equipment approved by the 

Executive Secretary. Calibration procedure and frequency shall be according to 

manufacturers specifications. Use of factory calibrated thermocouples for 

temperature measurement is approved. All monitoring equipment for both 

temperature and oxygen shall be located such that an inspector can safely read 

the output at any time. 

Additionally, the permittee shall monitor the quantities and times that used oil or 

TDF is burned in kiln. 

II.B.6.g.2 Recordkeeping: 

Permittee shall record the temperature and oxygen content at no less than every 5 

minutes during operations when used oil or TDF is burned in the kiln. The 

permittee shall record the quantities and times when used oil or TDF is burned in 

the kiln. 

Issued December 1, 2006 Page 32 Title V Operating Permit #2300015002 
II.B.6.g.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.h Condition: 

The concentration of contaminants or parameters in any used oil fuel burned in the Kiln 

shall not exceed the following levels: Arsenic 5 ppm by weight, Barium 100 ppm by 

weight, Cadmium 2 ppm by weight, Chromium 10 ppm by weight, Lead 100 ppm by 

weight, Total Halogens 1,000 ppm by weight, Sulfur 0.5 percent by weight, and Flash 

Point not less than 100 degrees F. Used oil exceeding any of the above contaminants 

shall not be burned until the permittee has submitted and received approval of a modeling 

analysis of the projected emissions for each contaminant from the Executive Secretary. 

The modeling analysis shall show in each case that the resulting concentration of 

contaminant in the ambient air does not exceed the TLV/100 value at the fence line for 

the given contaminant. Any used oil fuel that contains more than 1,000 ppm by weight of 

total halogens shall be considered a hazardous waste and shall not be burned in the kiln. 

[Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06] 

II.B.6.h.1 Monitoring: 

The permittee shall maintain test certification data for each load of used oil fuel 

received. Certification shall be either by permittee testing or test reports 

provided by the used oil fuel vendor. The used oil fuel shall be tested for 

halogen content by ASTM Method D-808-81, EPA Method 8240 or Method 

8260 before used oil fuel is transferred to a holding tank or burned. 

II.B.6.h.2 Recordkeeping: 

Records of used oil fuel consumption and the test reports shall be kept for all 

periods when the plant is in operation. 

II.B.6.h.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.i Condition: 

As part of demonstration of compliance with the dioxin/furan emission limitation in this 

permit, the permittee shall operate the kiln such that the temperature of the gas at the inlet 

to the kiln particulate matter control device (PMCD) and alkali bypass PMCD, if 

applicable, does not exceed the applicable temperature limits (for both raw mill operating 

and not operating) as determined and established in accordance with 40 CFR 

63.1349(b)(3)(iv). The permittee shall conduct an inspection of the components of the 

combustion system of each kiln or in-line kiln/raw mill at least once per year. [Authority 

granted under 40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 (Subpart 

LLL)] 

II.B.6.i.1 Monitoring: 

(a) The permittee shall install, calibrate, maintain, and continuously operate a 

continuous monitor to record the temperature of the exhaust gases from the 

kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to, or 

upstream of, PM control devices. The recorder response range shall include 

zero and 1.5 times either of the average temperatures established during the 

Issued December 1, 2006 Page 33 Title V Operating Permit #2300015002 
performance test. The reference method shall be a National Institute of 

Standards and Technology calibrated reference thermocouple-potentiometer 

system or alternate reference, subject to approval. 

(b) The permittee shall monitor and continuously record the temperature of the 

exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if 

applicable, at the inlet to the PM control device. 

(c) The three hour rolling average temperature shall be calculated as the average 

180 successive one-minute average temperatures. 

(d) Periods of time when one-minute averages are not available shall be ignored 

when calculating three-hour rolling averages. When one-minute averages 

become available, the first one-minute average is added to the previous 179 

values to calculate the three-hour rolling average. 

(e) When the operating status of the raw mill of the in-line kiln/raw mill is 

changed from off to on, or from on to off the calculation of the three-hour 

rolling average temperature must begin anew, without considering previous 

recordings. 

(f) The calibration of all thermocouples and other temperature sensors shall be 

verified at least once every three months. 

II.B.6.i.2 Recordkeeping: 

The permittee shall comply with the recordkeeping requirements specified in 

63.10 of the general provisions of 40 CFR 63, and those specified in Section I of 

this permit. Additionally, the permittee shall keep a log of the annual inspections 

of the components of the combustion system of each kiln or in-line kiln/raw mill. 

II.B.6.i.3 Reporting: 

The permittee shall comply with the reporting requirements specified in 63.10 of 

the general provisions of 40 CFR 63, Subpart A, provisions of 40 CFR 63.1354, 

and those specified in Section I of this permit. 

II.B.6.j Condition: 

Emissions of Dioxins/Furans (D/F) shall be no greater than 0.20 ng per dscm (8.7 x 10 ^-

11 gr per dscf) (TEQ) corrected to seven percent oxygen or 0.40 ng per dscm (1.7 x 10 ^-

10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the average of the 

performance test run average temperatures at the inlet to the particulate matter control 

device is 204 deg. C (400 deg. F) or less. [Authority granted under 40 CFR 63 (Subpart 

LLL); condition originated in 40 CFR 63 (Subpart LLL)] 

II.B.6.j.1 Monitoring: 

(a) Frequency. Emissions shall be tested every 30 months. The source may also 

be tested at any time if directed by the Executive Secretary. 

(b) Notification. At least 60 days before the test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy of 

the test protocol. The source shall attend a pretest conference if determined 

necessary by the Executive Secretary. 

(c) Methods. 

 (1) Sample Location - the emission point shall conform to the 

requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety 

Issued December 1, 2006 Page 34 Title V Operating Permit #2300015002 
and Health Administration (OSHA) or Mine Safety and Health Administration 

(MSHA) approved access shall be provided to the test location. 

 (2) 40 CFR 60, Appendix A, Method 23 shall be used to determine the 

pollutant emission rate. 

 (3) 40 CFR 60, Appendix A, Method 2 shall be used to determine the 

volumetric flow rate. 

 (4) Performance tests shall be conducted separately while the raw mill of 

the in-line kiln/raw mill is under normal operating conditions and while the raw 

mill of the in-line kiln/raw mill is not operating. If the kiln or in-line kiln/raw 

mill is equipped with an alkali bypass, simultaneous performance tests of the kiln 

or in-line kiln/raw mill exhaust and the alkali bypass shall be performed; 

however, a performance test of the alkali bypass exhaust may be conducted when 

the raw mill of the in-line kiln/raw mill is not operating. 

 (5) Each performance test shall consist of three separate runs; each run 

shall be conducted under the conditions that exist when the affected source is 

operating at the representative performance conditions in accordance with 40 

CFR 63.7(e). The duration of each run shall be at least 3 hours, and the sample 

volume for each run shall be at least 2.5 dscm (90 dscf). 

 (6) The temperature at the inlet to the kiln or in-line kiln/raw mill 

PMCD, and where applicable, the temperature at the inlet to the alkali bypass 

PMCD, must be continuously recorded during the period of the Method 23 test, 

and the continuous temperature record(s) must be included in the performance 

test report. 

 (7) One-minute average temperatures shall be calculated for each minute 

of each run of the test. 

 (8) The run average temperature must be calculated for each run, and the 

average of the run average temperatures must be determined and included in the 

performance test report and will determine the applicable temperature limit in 

accordance with 40 CFR 63.1344(b). 

 (9) If activated carbon injection is used for D/F control, the rate of 

activated carbon injection to the kiln or in-line kiln/raw mill exhaust, and where 

applicable, the rate of activated carbon injection to the alkali bypass exhaust, 

must be continuously recorded during the period of the Method 23 test, and the 

continuous injection rate record(s) must be included in the performance test 

report. In addition, the performance test report must include the brand and type of 

activated carbon used during the performance test and a continuous record of 

either the carrier gas flow rate or the carrier gas pressure drop for the duration of 

the test. The run average injection rate must be calculated for each run, and the 

average of the run average injection rates must be determined and included in the 

performance test report and will determine the applicable injection rate limit in 

accordance with §63.1344(c)(1). 

Issued December 1, 2006 Page 35 Title V Operating Permit #2300015002 
(d) Calculations. The concentration shall be determined for each test run, and 

the arithmetic average of the concentrations measured for the three runs shall be 

calculated and used to determine compliance. 

II.B.6.j.2 Recordkeeping: 

Results of all stack testing shall be recorded and maintained in accordance with 

the associated test method and Provision S.1 in Section I of this permit. 

II.B.6.j.3 Reporting: 

The results of stack testing shall be submitted to the Executive Secretary within 

60 days of completion of the testing. Reports shall clearly identify results as 

compared to permit limits and indicate compliance status. There are no 

additional reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.k Condition: 

Sulfur content of fuel burned shall be no greater than 1.0 lbs sulfur/MMBtu for any 

mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil except 

used oil or 0.5 percent by weight for any used oil. [Authority granted under R307-401-

8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06] 

II.B.6.k.1 Monitoring: 

Certification of fuels shall be either by permittee’s testing or test reports from the 

fuel marketer. Methods for determining sulfur content of coal and fuel oil shall 

be those methods of the American Society for Testing and Materials, UAC R307-

203-1(4) 

( a ) For determining sulfur content in coal, ASTM Methods D3177-75 or 

D4239-85 are to be used. 

( b ) For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-

89 are to be used. 

( c ) For determining the gross calorific (or Btu) content of coal, ASTM Methods 

D2015-77 or D3286-85 are to be used. 

II.B.6.k.2 Recordkeeping: 

Compliance with the above limitation shall be demonstrated by maintaining fuel 

receipt records showing sulfur content of the delivered fuel or maintaining 

records of all sulfur content testing performed on the delivered fuel. 

II.B.6.k.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.l Condition: 

Emissions of CO shall be no greater than 13,045 tons per rolling 12-month period and 

6,600 pounds per hour. [Authority granted under R307-401-8(1)(a) [BACT]; condition 

originated in DAQE-AN0303012-06] 

II.B.6.l.1 Monitoring: 

While the affected emission unit is operating, hourly CO emission rates 

expressed in tons per hour shall be determined in accordance with R307-170 

Issued December 1, 2006 Page 36 Title V Operating Permit #2300015002 
using the appropriate conversion factors. The applicable performance 

specification in R307-170 shall be 40 CFR 60, Appendix B, Performance 

Specification 6 - "Specifications and Test Procedures for Continuous Emission 

Rate Monitoring Systems in Stationary Sources". By the 25th day of each month 

a new 12-month CO emission total for the common stack shall be calculated as 

the sum of the monthly CO emission totals for each of the previous 12 months. 

II.B.6.l.2 Recordkeeping: 

The permittee shall keep the records specified in R307-170-8 and any additional 

records required by provision I.S.1 of this permit. These records shall be 

maintained in accordance with Provision I.S.1. 

II.B.6.l.3 Reporting: 

The permittee shall comply with the reporting provisions in R307-170-9 and any 

additional reporting provisions contained in Section I of this permit. 

The quarterly reports required in R307-170-9 are considered prompt notification 

of permit deviations required in Provision I.S.2.c of this permit if all information 

required by Provision I.S.2.c is included in the report. 

II.B.6.m Condition: 

Production of clinker shall be no greater than 962,265 tons per 12-month rolling period. 

[Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06] 

II.B.6.m.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.6.m.2 Recordkeeping: 

Daily records of clinker production and kiln feed rates shall be kept for all 

periods of operation. By the 25th day of each month, a new 12-month total shall 

be calculated for clinker production using data from the previous 12 months. 

Records shall be kept in a supervisor log and in accordance with Provision I.S.1 

of this permit. 

II.B.6.m.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.6.n Condition: 

No greater than 10 percent of the kiln gases shall be routed to the Coal Grinding System 

(designated as 41B.BF2). [Authority granted under 40 CFR 63.8(f) (Subpart A); 

condition originated in Alternative Monitoring EPA Approval 11/6/02] 

II.B.6.n.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.6.n.2 Recordkeeping: 

Records verifying the percent of kiln gases routed to the coal grinding system 

shall be maintained in accordance with Provision I.S.1 of this permit and made 

available for review by the Executive Secretary or his representative. 

Issued December 1, 2006 Page 37 Title V Operating Permit #2300015002 
II.B.6.n.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.7 Conditions on Clinker Cooler (419.BF1)

II.B.7.a Condition: 

Emissions of particulate matter shall be no greater than 0.10 lbs per ton (0.050 kg/Mg) of 

kiln feed (dry basis). [Authority granted under R307-401-8(1)(a) [BACT] & 40 CFR 63 

(Subpart LLL); condition originated in 40 CFR 63 (Subpart LLL)] 

II.B.7.a.1 Monitoring: 

Stack testing shall be performed as specified below: 

(a) Frequency. Emissions shall be tested every five (5) years, based on the date 

of the most recent stack test. Tests may also be required at the direction of the 

Executive Secretary. 

(b) Notification. At least 60 days before the test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy of 

the test protocol. The source shall attend a pretest conference if determined 

necessary by the Executive Secretary. 

(c) Methods. 

 (1) Sample Location - the emission point shall conform to the 

requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety 

and Health Administration (OSHA) or Mine Safety and Health Administration 

(MSHA) approvable access shall be provided to the test location. 

 (2) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used 

to determine particulate matter emissions and the volumetric flow rate of the 

effluent gas. Each test shall consist of three separate runs. Each run shall be 

conducted for at least one hour, and the minimum sample volume shall be 0.85 

dscm (30 dscf). The average of the three runs shall be used to determine 

compliance. The emission rate of particulate matter shall be computed for each 

run using the equation in 40 CFR 63.1349(b)(1). 

(d) Production Rate During Testing. The production rate during all compliance 

testing shall be no less than 90% of the maximum production achieved in the 

previous three (3) years. 

II.B.7.a.2 Recordkeeping: 

Results of all stack testing shall be recorded and maintained in accordance with 

the associated test method and Provision S.1 in Section I of this permit. 

II.B.7.a.3 Reporting: 

The results of stack testing shall be submitted to the Executive Secretary within 

60 days of completion of the testing. Reports shall clearly identify results as 

compared to permit limits and indicate compliance status. There are no 

Issued December 1, 2006 Page 38 Title V Operating Permit #2300015002 
additional reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.7.b Condition: 

Emissions of PM10 shall be no greater than 10.4 lbs/hr. [Authority granted under R307-

401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06] 

II.B.7.b.1 Monitoring: 

(a) Stack testing shall be performed as specified below: 

(i) Frequency. Emissions shall be tested every three years. The source may 

also be tested at any time if directed by the Executive Secretary. 

(ii) Notification. At least 30 days before the test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy 

of the test protocol. The source shall attend a pretest conference if 

determined necessary by the Executive Secretary. 

(iii) Methods. 

a. Sample Location - the emission point shall conform to the 

requirements of 40 CFR 60, Appendix A, Method 1, and Occupational 

Safety and Health Administration (OSHA) approved access shall be 

provided to the test location. 

b. For stacks in which no liquid drops are present, the following 

methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. 

Method 202 may be used to measure condensible particulate matter. 

c. For stacks in which liquid drops are present, methods to eliminate 

the liquid drops should be explored. If no reasonable method to eliminate 

the drops exists, then the following methods shall be used: 40 CFR 60, 

Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half 

condensibles shall also be tested using a method specified by the 

Executive Secretary. All particulate captured shall be considered PM10. 

d. The back half condensibles shall not be used for compliance 

demonstration but shall be used for inventory purposes. 

(iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant 

concentration as determined by the appropriate methods above shall be 

multiplied by the volumetric flow rate and any necessary conversion factors 

determined by the Executive Secretary to give the results in the specified 

units of the emission limitation. 

(v) Production Rate During Testing. The production rate during all 

compliance testing shall be no less than 90% of the maximum production 

achieved in the previous three (3) years. 

(b) Optical density shall be used as an indicator to provide reasonable assurance 

of compliance with the PM10 emission limitation as specified below. 

(i) Measurement Approach: Opacity shall be determined using a continuous 

opacity monitor (COM) located in the exhaust stack. The opacity shall 

be mathematically converted to units of optical density. 

(ii) Indicator Range: An excursion is defined as a 24-hour block average 

optical density in excess of 0.046 excluding periods of startup, shutdown, 

or malfunction. Excursions trigger an inspection, corrective action, and a 

reporting requirement. Provision II.B.7.b.1(b)(ii) of this permit does not 

constitute a waiver, or a shield against enforcement, of Provision II.B.7.c 

of this permit. 

Issued December 1, 2006 Page 39 Title V Operating Permit #2300015002 
Once every three years, during the stack test required in (a) above, the 

permittee shall acquire new test data to evaluate or update the excursion 

optical density value. The procedure for collecting new test data is 

described in a reviewer comment at the end of this permit. 

(iii) Performance Criteria: 

a. Data Representativeness: The COM shall be installed in a 

representative location in the exhaust stack and shall be calibrated, 

maintained, and operated in accordance with 40 CFR Part 60 

Appendix B Performance Specification 1 and R307-170. 

b. QA/QC Practices and Criteria: The COM shall be calibrated, 

maintained, and operated in accordance with 40 CFR Part 60 

Appendix B Performance Specification 1, R307-170, and the 

manufacturer’s written recommendations. 

c. Monitoring Frequency: Opacity shall be monitored continuously and 

a data point recorded electronically every 10 seconds. 

d. Data Collection Procedure: The 10-second opacity data shall be 

used to calculate 6-minute opacity averages. The 6-minute opacity 

averages shall be mathematically converted to units of optical 

density. The 6-minute optical density values shall be averaged over 

a 1-hour block. The 1-hour optical density averages shall be used to 

calculate a 24-hour block average. The 24-hour block average 

optical density shall be recorded and stored electronically. 

e. Averaging Period: 24-hour block average. 

II.B.7.b.2 Recordkeeping: 

Results of all stack testing shall be recorded and maintained in accordance with 

the associated test method and Provision I.S.1 of this permit. 

Records of the 24-hour block average optical density values shall be maintained 

in accordance with Provision I.S.1 of this permit. In addition, the permittee shall 

maintain records of: 

a) all test data from the most recent stack test and the calculations that were 

used to evaluate or revise the excursion optical density value. 

b) all continuous opacity monitor (COM) parameters, performance test 

measurements, all COM performance evaluations, all COM calibration 

checks, all COM adjustments and maintenance, and all other information 

required by R307-170 in a permanent form suitable for inspection. 

c) the occurrence and duration of any excursion, corrective actions taken, 

and any other supporting information required to be maintained under 40 

CFR 64 (such as data used to document the adequacy of monitoring, or 

records of monitoring maintenance or corrective actions). Instead of 

paper records, the permittee may maintain records on alternative media, 

such as microfilm, computer files, magnetic tape disks, or microfiche, 

provided that the use of such alternative media allows for expeditious 

inspection and review, and does not conflict with other applicable 

recordkeeping requirements. (40 CFR 64.9(b)) 

II.B.7.b.3 Reporting: 

In addition to the reporting requirements in Provision I.S.2 of this permit, 

(a) Monitoring reports shall include, at a minimum, the following information, 

as applicable: 

Issued December 1, 2006 Page 40 Title V Operating Permit #2300015002 
(i) Summary information on the number, duration and cause (including 

unknown cause, if applicable) of excursions or exceedances, as 

applicable, and the corrective actions taken; (40 CFR 64.9(a)(2)(i)) 

(ii) Summary information on the number, duration and cause (including 

unknown cause, if applicable) for monitor downtime incidents (other 

than downtime associated with zero and span or other daily calibration 

checks, if applicable). (40 CFR 64.9(a)(2)(ii)) 

(b) The results of stack testing shall be submitted to the Executive Secretary 

within 60 days of completion of the testing. Reports shall clearly identify 

results as compared to permit limits and indicate compliance status. 

II.B.7.c Condition: 

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 

40 CFR 63 (Subpart LLL); condition originated in DAQE-AN0303012-06] 

II.B.7.c.1 Monitoring: 

The permittee shall calibrate, maintain and operate a continuous monitoring 

system for measuring the opacity of emissions discharged to the atmosphere in 

accordance with R307-170 and 40 CFR 63.8 (Subpart A), and shall record the 

output of the system. The output shall be reviewed at least monthly for 

compliance with the opacity limit; compliance is to be based on the percent 

opacity averaged over six consecutive minutes. 

II.B.7.c.2 Recordkeeping: 

Results of opacity observations shall be recorded and maintained as required in 

R307-170 and as described in Provision I.S.1 of this permit. 

II.B.7.c.3 Reporting: 

The permittee shall comply with the reporting provisions in R307-170-9 and any 

additional reporting provisions contained in Section I of this permit. 

The quarterly reports required in R307-170-9 are considered prompt notification 

of permit deviations required in Provision I.S.2.c of this permit if all information 

required by Provision I.S.2.c is included in the report. 

II.B.8 Conditions on Finish Mill (514.BF2)

II.B.8.a Condition: 

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 

40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 (Subpart LLL) & DAQEAN0303012-06] 

II.B.8.a.1 Monitoring: 

A. The permittee shall monitor opacity by conducting daily visual emissions 

observations of the mill sweep and air separator PMCD in accordance with 

the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test 

shall be conducted while the affected source is operating at the representative 

performance conditions. The duration of the Method 22 test shall be 6 

minutes. If visible emissions are observed during any Method 22 visible 

emissions test, the permittee must: 

Issued December 1, 2006 Page 41 Title V Operating Permit #2300015002 
(1) Initiate, within one-hour, the corrective actions specified in the site 

specific operating and maintenance plan developed in accordance with 

condition II.B.1.g of this permit; and 

(2) Within 24 hours of the end of the Method 22 test in which visible 

emissions were observed, conduct a followup Method 22 test of each 

stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are observed during the followup 

Method 22 test from any stack from which visible emissions were 

observed during the previous Method 22 test, conduct a visual opacity 

test of each stack from which emissions were observed during the follow 

up Method 22 test in accordance with 40 CFR 60, Appendix A, Method 

9. The duration of the Method 9 test shall be 30 minutes. [origin: 40 

CFR 63.1350(e) and Table 1 to 63.1350] 

B. In lieu of the daily visual emissions testing required in paragraph A. above, 

the permittee may choose to install a continuous opacity monitor (COM) or 

bag leak detection system (BLDS). 

(1) If the permittee chooses to install a COM, it must be installed at the 

outlet of the PM control device of the mill. The COM must be installed, 

maintained, calibrated, and operated as required by 40 CFR 60, 

Appendix B, PS-1-'Specifications and Test Procedures for Continuous 

Opacity Monitoring Systems in Stationary Sources', 40 CFR 63.8 

(Subpart A), and R307-170. To remain in compliance, the opacity must 

be maintained such that the 6-minute average opacity for any 6-minute 

block period does not exceed 10 percent. If the average opacity for any 

6-minute block period exceeds 10 percent, this shall constitute a 

violation of the standard. COM output shall be recorded. The output 

shall be reviewed at least monthly for compliance. 

(2) If the permittee chooses to install a BLDS, the following requirements 

apply to each BLDS: 

(a) The BLDS must be certified by the manufacturer to be capable of 

detecting PM emissions at concentrations of 10 milligrams per actual 

cubic meter (0.0044 grains per actual cubic foot) or less. "Certify" 

shall mean that the instrument manufacturer has tested the instrument 

on gas streams having a range of particle size distributions and 

confirmed by means of valid filterable PM tests that the minimum 

detectable concentration limit is at or below 10 milligrams per actual 

cubic meter (0.0044 grains per actual cubic foot) or less. 

(b) The sensor on the BLDS must provide output of relative PM 

emissions. 

(c) The BLDS must have an alarm that will activate automatically when 

it detects a significant increase in relative PM emissions greater than 

a preset level. 

(d) The presence of an alarm condition should be clearly apparent to 

facility operating personnel. 

(e) For a positive-pressure fabric filter, each compartment or cell must 

have a bag leak detector. For a negative-pressure or induced-air 

fabric filter, the bag leak detector must be installed downstream of 

the fabric filter. If multiple bag leak detectors are required (for either 

type of fabric filter), detectors may share the system instrumentation 

and alarm. 

Issued December 1, 2006 Page 42 Title V Operating Permit #2300015002 
(f) All BLDS must be installed, operated, adjusted, and maintained so 

that they are based on the manufacturer's written specifications and 

recommendations. 

(g) The baseline output of the system must be established as follows: 

(i) Adjust the range and the averaging period of the device; and 

(ii) Establish the alarm set points and the alarm delay time. 

(h) After initial adjustment, the range, averaging period, alarm set 

points, or alarm delay time may not be adjusted except as specified 

in the operations and maintenance plan required by 40 CFR 

63.1350(a). In no event may the range be increased by more than 100 

percent or decreased by more than 50 percent over a 1 calendar year 

period unless a responsible official as defined in R307-415-3 

certifies in writing to the Executive Secretary that the fabric filter has 

been inspected and found to be in good operating condition. 

(i) The permittee must maintain and operate the fabric filter such that 

the bag leak detector alarm is not activated and alarm condition does 

not exist for more than 5 percent of the total operating time in a 6-

month block period. Each time the alarm activates, alarm time will 

be counted as the actual amount of time taken by the owner or 

operator to initiate corrective actions. If inspection of the fabric filter 

demonstrates that no corrective actions are necessary, no alarm time 

will be counted. 

[origin: 40 CFR 63.1350(m)] 

C. Once every five years, the permittee shall demonstrate compliance with the 

opacity limit by conducting a test in accordance with 40 CFR 60, Appendix 

A, Method 9. The performance test shall be conducted under normal 

operating conditions in accordance with 40 CFR 63.7(e). The maximum 6-

minute average opacity exhibited during the test period shall be used to 

determine whether the affected source is in compliance with the standard. 

The duration of the Method 9 performance test shall be 3 hours (30 6-minute 

averages), except that the duration of the Method 9 performance test may be 

reduced to 1 hour if the conditions of paragraphs (i) and (ii) apply: 

(i) There are no individual readings greater than 10 percent opacity; 

(ii) There are no more than three readings of 10 percent for the first 1-hour 

period. 

(origin: 40 CFR 63.1349(b)(2), 40 CFR 63.1349(c)) 

At least 60 days before the performance test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy 

of the test protocol. The source shall attend a pretest conference if 

determined necessary by the Executive Secretary. [origin: 40 CFR 63.9(e) 

via 40 CFR 63.1353(b)(2), (3)] 

II.B.8.a.2 Recordkeeping: 

The permittee shall maintain files of all information (including all reports and 

notifications) required by this condition in a form suitable and readily available 

for expeditious inspection and review. These files shall be retained for at least 

five years following the date of each occurrence, measurement, maintenance, 

corrective action, report or record. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be retained 

off site. The files may be maintained on microfilm, on a computer, on floppy 

Issued December 1, 2006 Page 43 Title V Operating Permit #2300015002 
disks, on magnetic tape, or on microfiche. Requirements of Provision I.S.1 of 

this permit also apply. [origin: 40 CFR 63.1355] 

Additionally, records of visual emission observations and visual opacity tests 

required by 40 CFR 60, Appendix A, Methods 22 and 9 shall be maintained in 

accordance with Provision I.S.1 of this permit if a COM or BLDS is not used. 

If the COM option is used, results of opacity observations from the COM shall be 

recorded and maintained as required in R307-170, 40 CFR 63.10(c), and as 

described in Provision I.S.1 of this permit. 

If the BLDS monitoring option is chosen, the following additional records shall 

be maintained in accordance with Provision I.S.1 of this permit: 

(1) The permittee shall continuously record the output from the BLDS during 

periods of normal operation. Normal operation does not include periods 

when the BLDS is being maintained or during startup, shutdown or 

malfunction. 

(2) Alarm times, as defined in the above monitoring, shall be recorded. 

II.B.8.a.3 Reporting: 

In addition to the reporting requirements of Provision I.S.1 of this permit, the 

reporting requirements of R307-170, 40 CFR 63.10(e), and 40 CFR 63.1354 also 

apply if a continuous monitoring method is used. 

The five-year performance test results shall be documented in complete test 

reports that contain the information required by paragraphs (i) through (x), as 

well as all other relevant information. The plan to be followed during testing 

shall be made available to the Executive Secretary prior to testing, if requested. 

(i) A brief description of the process and the air pollution control system; 

(ii) Sampling location description(s); 

(iii) A description of sampling and analytical procedures and any modifications 

to standard procedures; 

(iv) Test results; 

(v) Quality assurance procedures and results; 

(vi) Records of operating conditions during the test, preparation of standards, 

and calibration procedures; 

(vii) Raw data sheets for field sampling and field and laboratory analyses; 

(viii) Documentation of calculations; 

(ix) All data recorded and used to establish parameters for compliance 

monitoring; and 

(x) Any other information required by the test method. 

(origin: 40 CFR 63.1349(a)) 

II.B.9 Conditions on Finish Mill Separator (514.BF1)

II.B.9.a Condition: 

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 

40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 (Subpart LLL) & DAQEAN0303012-06] 

Issued December 1, 2006 Page 44 Title V Operating Permit #2300015002 
II.B.9.a.1 Monitoring: 

A. The permittee shall monitor opacity by conducting daily visual emissions 

observations of the mill sweep and air separator PMCD in accordance with 

the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test 

shall be conducted while the affected source is operating at the representative 

performance conditions. The duration of the Method 22 test shall be 6 

minutes. If visible emissions are observed during any Method 22 visible 

emissions test, the permittee must: 

(1) Initiate, within one-hour, the corrective actions specified in the site 

specific operating and maintenance plan developed in accordance with 

condition II.B.1.g of this permit; and 

(2) Within 24 hours of the end of the Method 22 test in which visible 

emissions were observed, conduct a followup Method 22 test of each 

stack from which visible emissions were observed during the previous 

Method 22 test. If visible emissions are observed during the followup 

Method 22 test from any stack from which visible emissions were 

observed during the previous Method 22 test, conduct a visual opacity 

test of each stack from which emissions were observed during the follow 

up Method 22 test in accordance with 40 CFR 60, Appendix A, Method 

9. The duration of the Method 9 test shall be 30 minutes. [origin: 40 

CFR 63.1350(e) and Table 1 to 63.1350] 

B. In lieu of the daily visual emissions testing required in paragraph A. above, 

the permittee may choose to install a continuous opacity monitor (COM) or 

bag leak detection system (BLDS). 

(1) If the permittee chooses to install a COM, it must be installed at the 

outlet of the PM control device of the mill. The COM must be installed, 

maintained, calibrated, and operated as required by 40 CFR 60, 

Appendix B, PS-1-'Specifications and Test Procedures for Continuous 

Opacity Monitoring Systems in Stationary Sources', 40 CFR 63.8 

(Subpart A), and R307-170. To remain in compliance, the opacity must 

be maintained such that the 6-minute average opacity for any 6-minute 

block period does not exceed 10 percent. If the average opacity for any 

6-minute block period exceeds 10 percent, this shall constitute a 

violation of the standard. COM output shall be recorded. The output 

shall be reviewed at least monthly for compliance. 

(2) If the permittee chooses to install a BLDS, the following requirements 

apply to each BLDS: 

(a) The BLDS must be certified by the manufacturer to be capable of 

detecting PM emissions at concentrations of 10 milligrams per actual 

cubic meter (0.0044 grains per actual cubic foot) or less. "Certify" 

shall mean that the instrument manufacturer has tested the instrument 

on gas streams having a range of particle size distributions and 

confirmed by means of valid filterable PM tests that the minimum 

detectable concentration limit is at or below 10 milligrams per actual 

cubic meter (0.0044 grains per actual cubic foot) or less. 

(b) The sensor on the BLDS must provide output of relative PM 

emissions. 

(c) The BLDS must have an alarm that will activate automatically when 

it detects a significant increase in relative PM emissions greater than 

a preset level. 

Issued December 1, 2006 Page 45 Title V Operating Permit #2300015002 
(d) The presence of an alarm condition should be clearly apparent to 

facility operating personnel. 

(e) For a positive-pressure fabric filter, each compartment or cell must 

have a bag leak detector. For a negative-pressure or induced-air 

fabric filter, the bag leak detector must be installed downstream of 

the fabric filter. If multiple bag leak detectors are required (for either 

type of fabric filter), detectors may share the system instrumentation 

and alarm. 

(f) All BLDS must be installed, operated, adjusted, and maintained so 

that they are based on the manufacturer's written specifications and 

recommendations. 

(g) The baseline output of the system must be established as follows: 

(i) Adjust the range and the averaging period of the device; and 

(ii) Establish the alarm set points and the alarm delay time. 

(h) After initial adjustment, the range, averaging period, alarm set 

points, or alarm delay time may not be adjusted except as specified 

in the operations and maintenance plan required by 40 CFR 

63.1350(a). In no event may the range be increased by more than 100 

percent or decreased by more than 50 percent over a 1 calendar year 

period unless a responsible official as defined in R307-415-3 

certifies in writing to the Executive Secretary that the fabric filter has 

been inspected and found to be in good operating condition. 

(i) The permittee must maintain and operate the fabric filter such that 

the bag leak detector alarm is not activated and alarm condition does 

not exist for more than 5 percent of the total operating time in a 6-

month block period. Each time the alarm activates, alarm time will 

be counted as the actual amount of time taken by the owner or 

operator to initiate corrective actions. If inspection of the fabric filter 

demonstrates that no corrective actions are necessary, no alarm time 

will be counted. 

[origin: 40 CFR 63.1350(m)] 

C. Once every five years, the permittee shall demonstrate compliance with the 

opacity limit by conducting a test in accordance with 40 CFR 60, Appendix 

A, Method 9. The performance test shall be conducted under normal 

operating conditions in accordance with 40 CFR 63.7(e). The maximum 6-

minute average opacity exhibited during the test period shall be used to 

determine whether the affected source is in compliance with the standard. 

The duration of the Method 9 performance test shall be 3 hours (30 6-minute 

averages), except that the duration of the Method 9 performance test may be 

reduced to 1 hour if the conditions of paragraphs (i) and (ii) apply: 

(i) There are no individual readings greater than 10 percent opacity; 

(ii) There are no more than three readings of 10 percent for the first 1-hour 

period. 

(origin: 40 CFR 63.1349(b)(2), 40 CFR 63.1349(c)) 

At least 60 days before the performance test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy 

of the test protocol. The source shall attend a pretest conference if 

determined necessary by the Executive Secretary. [origin: 40 CFR 63.9(e) 

via 40 CFR 63.1353(b)(2), (3)] 

Issued December 1, 2006 Page 46 Title V Operating Permit #2300015002 
II.B.9.a.2 Recordkeeping: 

The permittee shall maintain files of all information (including all reports and 

notifications) required by this condition in a form suitable and readily available 

for expeditious inspection and review. These files shall be retained for at least 

five years following the date of each occurrence, measurement, maintenance, 

corrective action, report or record. At a minimum, the most recent two years of 

data shall be retained on site. The remaining three years of data may be retained 

off site. The files may be maintained on microfilm, on a computer, on floppy 

disks, on magnetic tape, or on microfiche. Requirements of Provision I.S.1 of 

this permit also apply. [origin: 40 CFR 63.1355] 

Additionally, records of visual emission observations and visual opacity tests 

required by 40 CFR 60, Appendix A, Methods 22 and 9 shall be maintained in 

accordance with Provision I.S.1 of this permit if a COM or BLDS is not used. 

If the COM option is used, results of opacity observations from the COM shall be 

recorded and maintained as required in R307-170, 40 CFR 63.10(c), and as 

described in Provision I.S.1 of this permit. 

If the BLDS monitoring option is chosen, the following additional records shall 

be maintained in accordance with Provision I.S.1 of this permit: 

(1) The permittee shall continuously record the output from the BLDS during 

periods of normal operation. Normal operation does not include periods 

when the BLDS is being maintained or during startup, shutdown or 

malfunction. 

(2) Alarm times, as defined in the above monitoring, shall be recorded. 

II.B.9.a.3 Reporting: 

In addition to the reporting requirements of Provision I.S.1 of this permit, the 

reporting requirements of R307-170, 40 CFR 63.10(e), and 40 CFR 63.1354 also 

apply if a continuous monitoring method is used. 

The five-year performance test results shall be documented in complete test 

reports that contain the information required by paragraphs (i) through (x), as 

well as all other relevant information. The plan to be followed during testing 

shall be made available to the Executive Secretary prior to testing, if requested. 

(i) A brief description of the process and the air pollution control system; 

(ii) Sampling location description(s); 

(iii) A description of sampling and analytical procedures and any modifications 

to standard procedures; 

(iv) Test results; 

(v) Quality assurance procedures and results; 

(vi) Records of operating conditions during the test, preparation of standards, 

and calibration procedures; 

(vii) Raw data sheets for field sampling and field and laboratory analyses; 

(viii) Documentation of calculations; 

Issued December 1, 2006 Page 47 Title V Operating Permit #2300015002 
(ix) All data recorded and used to establish parameters for compliance 

monitoring; and 

(x) Any other information required by the test method. 

(origin: 40 CFR 63.1349(a)) 

II.B.10 Conditions on Materials Handling Operation (MHO)

II.B.10.a Condition: 

Visible emissions shall be no greater than 10 percent opacity from each affected unit. 

[Authority granted under 40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 

(Subpart LLL)] 

II.B.10.a.1 Monitoring: 

(a) Monitoring of visible emissions shall be performed as follows: 

(1) The permittee shall conduct a monthly 1-minute visible emissions test of 

each affected source in accordance with 40 CFR 60, Appendix A, 

Method 22. The test must be conducted while the affected source is in 

operation. 

(2) If no visible emissions are observed in six consecutive monthly tests for 

any affected source, the permittee may decrease the frequency of testing 

from monthly to semi-annually for that affected source. If visible 

emissions are observed during any semi-annual test, the permittee must 

resume testing of that affected source on a monthly basis and maintain 

that schedule until no visible emissions are observed in six consecutive 

monthly tests. 

(3) If no visible emissions are observed during the semi-annual test for any 

affected source, the permittee may decrease the frequency of testing from 

semi-annually to annually for that affected source. If visible emissions 

are observed during any annual test, the permittee shall resume testing of 

that affected source on a monthly basis and maintain that schedule until 

no visible emissions are observed in six consecutive monthly tests. 

(4) If visible emissions are observed during any Method 22 test, the 

permittee shall conduct a 6-minute test of opacity in accordance with 40 

CFR 60, Appendix A, Method 9. The Method 9 test must begin within 

one hour of any observation of visible emissions. 

(5) The requirement to conduct Method 22 visible emissions monitoring 

under this condition shall not apply to any totally enclosed conveying 

system transfer point, regardless of the location of the transfer point. 

"Totally enclosed conveying system transfer point" shall mean a 

conveying system transfer point that is enclosed on all sides, top, and 

bottom. The enclosures for these transfer points shall be operated and 

maintained as total enclosures on a continuing basis in accordance with 

the facility operations and maintenance plan. 

(6) If any partially enclosed or unenclosed conveying system transfer point 

is located in a building, the permittee shall have the option to conduct a 

Method 22 visible emissions monitoring test according to the 

requirements of paragraphs 1 through 4 of this condition for each such 

conveying system transfer point located within the building, or for the 

building itself, according to paragraph 7 of this condition. 

(7) If visible emissions from a building are monitored, the requirements of 

paragraphs 1 through 4 of this condition apply to the monitoring of the 

Issued December 1, 2006 Page 48 Title V Operating Permit #2300015002 
building, and the permittee shall also test visible emissions from each 

side, roof and vent of the building for at least 1 minute. The test must be 

conducted under normal operating conditions. 

(b) Once every five years, the permittee shall demonstrate compliance with the 

opacity limit by conducting a test in accordance with Method 9 of appendix 

A to 40 CFR Part 60. The performance test shall be conducted under normal 

operating conditions in accordance with 40 CFR 63.7(e). The maximum 6-

minute average opacity exhibited during the test period shall be used to 

determine whether the affected source is in compliance with the standard. 

The duration of the Method 9 performance test shall be 3 hours (30 6-minute 

averages), except that the duration of the Method 9 performance test may be 

reduced to 1 hour if the conditions of paragraphs (i) and (ii) apply: 

(i) There are no individual readings greater than 10 percent opacity; 

(ii) There are no more than three readings of 10 percent for the first 1-hour 

period. 

(origin: 40 CFR 63.1349(b)(2), 40 CFR 63.1349(c)) 

At least 60 days before the performance test, the source shall notify the 

Executive Secretary of the date, time, and place of testing and provide a copy 

of the test protocol. The source shall attend a pretest conference if 

determined necessary by the Executive Secretary. 

[origin: 40 CFR 63.9(e) via 40 CFR 63.1353(b)(2), (3)] 

II.B.10.a.2 Recordkeeping: 

The permittee shall maintain files of all information (including all reports and 

notifications) required by this condition in accordance with Provision I.S.1 of this 

permit and in a form suitable and readily available for expeditious inspection and 

review. These files shall be retained for at least five years following the date of 

each occurrence, measurement, maintenance, corrective action, report or record. 

At a minimum, the most recent two years of data shall be retained on site. The 

remaining three years of data may be retained off site. The files may be 

maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or 

on microfiche. 

In addition, results from opacity observations and all data required by 40 CFR 

60, Appendix A, Method 22 and 9 shall be recorded and maintained in 

accordance with Provision I.S.1 of this permit. (origin: 40 CFR 63.1355) 

II.B.10.a.3 Reporting: 

In addition to the reporting requirements specified in Section I of this permit, 

performance test results shall be documented in complete test reports that contain 

the information required by paragraphs (i) through (x), as well as all other 

relevant information. The plan to be followed during testing shall be made 

available to the Executive Secretary prior to testing, if requested. 

(i) A brief description of the process and the air pollution control system; 

(ii) Sampling location description(s); 

(iii) A description of sampling and analytical procedures and any modifications 

to standard procedures; 

(iv) Test results; 

(v) Quality assurance procedures and results; 

Issued December 1, 2006 Page 49 Title V Operating Permit #2300015002 
(vi) Records of operating conditions during the test, preparation of standards, 

and calibration procedures; 

(vii) Raw data sheets for field sampling and field and laboratory analyses; 

(viii) Documentation of calculations; 

(ix) All data recorded and used to establish parameters for compliance 

monitoring; and 

(x) Any other information required by the test method. 

(origin: 40 CFR 63.1349(a)) 

II.B.11 Conditions on Limestone Bypass System (LBS)

II.B.11.a Condition: 

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 

40 CFR 60.672(b) (Subpart OOO); condition originated in DAQE-AN0303012-06] 

II.B.11.a.1 Monitoring: 

A visual observation of each affected emission unit shall be performed on a 

weekly basis by an individual trained on the observation procedures of 40 CFR 

60, Appendix A, Method 9. The individual is not required to be a certified 

visible emissions observer (VEO). If any visible emissions are observed, an 

opacity determination of that emission unit shall be performed by a certified 

VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of 

the initial observation. For each affected emission unit, if no visible emissions 

are observed for eight consecutive weeks the observation frequency shall be 

reduced to a monthly basis. If visible emissions are observed during any monthly 

observation the frequency shall revert back to a weekly basis. 

II.B.11.a.2 Recordkeeping: 

Records of visual observations performed and data required by 40 CFR 60, 

Appendix A, Method 9 for each determination shall be maintained in accordance 

with Provision I.S.1 of this permit. 

II.B.11.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.11.b Condition: 

Throughput shall be no greater than 60,000 tons per 12-month rolling period. [Authority 

granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-

06] 

II.B.11.b.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.11.b.2 Recordkeeping: 

Daily records of limestone bypass throughput shall be kept for all periods of 

operation. By the 25th day of each month, a new 12-month total shall be 

calculated using data from the previous 12 months. Records shall be kept in a 

supervisor log and in accordance with Provision I.S.1 of this permit 

Issued December 1, 2006 Page 50 Title V Operating Permit #2300015002 
II.B.11.b.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.11.c Condition: 

Permittee shall operate water sprays or dust suppression sprays to control fugitive 

emissions. The sprays shall operate whenever dry conditions warrant or as determined 

necessary by the Executive Secretary. Sprays shall not be required during periods of 

freezing temperatures. [Authority granted under R307-401-8(1)(a) [BACT]; condition 

originated in DAQE-AN0303012-06] 

II.B.11.c.1 Monitoring: 

Visual inspections of the water spray system(s) shall be made weekly to ensure 

proper operating condition. 

II.B.11.c.2 Recordkeeping: 

An operator’s log shall be maintained of all monitoring provisions listed above. 

Records of water spray system inspections shall be kept for all periods of 

operation and the ambient temperature shall be recorded any time water should 

be applied but can not be due to freezing conditions. 

II.B.11.c.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

II.B.12 Conditions on Belt Conveyor Transfer Baghouse (311.BC1)

II.B.12.a Condition: 

The permittee shall notify the Executive Secretary in writing when the installation of new 

equipment in the affected unit has been completed and is operational, as an initial 

compliance inspection is required. To ensure proper credit when notifying the Executive 

Secretary, send your correspondence to the Executive Secretary, attn: Compliance 

Section. 

If installation has not been completed within eighteen months from the date of the 

approval order listed as "origin" for this condition, the Executive Secretary shall be 

notified in writing on the status of the installation. At that time, the Executive Secretary 

shall require documentation of the continuous installation of the operation and may 

revoke the AO in accordance with R307-401-18, UAC. [Authority granted under R307-

401-18; condition originated in DAQE-AN0303012-06] 

II.B.12.a.1 Monitoring: 

Records required for this permit condition will serve as monitoring. 

II.B.12.a.2 Recordkeeping: 

As applicable, the permittee shall maintain a copy of each notification required 

by this permit condition in accordance with Provision I.S.1 of this permit. 

II.B.12.a.3 Reporting: 

There are no reporting requirements for this provision except those specified in 

Section I of this permit. 

Issued December 1, 2006 Page 51 Title V Operating Permit #2300015002 
II.C. Emissions Trading. 

(R307-415-6a(10)) 

Not applicable to this source. 

II.D. Alternative Operating Scenarios. 

(R307-415-6a(9)) 

Not applicable to this source. 

Section III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance 

with Provision I.M, Permit Shield: 

III.A. 40 CFR 63.1349(b)(3), 63.1350(f), Subpart LLL (NESHAP from the Portland Cement 

Manufacturing Industry) 

This regulation is not applicable to the Coal Grinding System (41B.BF2) because EPA granted a 

waiver in a letter dated November 6, 2002 from Martin Hestmark, EPA, to Robert Vantuyl, Ash 

Grove. The waiver is contingent on Ash Grove's compliance with Conditions II.B.6.i, II.B.6.j, 

II.B.4.b, and II.B.6.n. of this permit. 

III.B. 40 CFR, Part 60, Subpart F (NSPS / Standards of Performance for Portland Cement Plants) 

This regulation is not applicable to the permitted source (Source-wide) because all Subpart F 

affected facilities are covered by 40 CFR 63 Subpart LLL. 

III.C. 40 CFR, Part 60, Subpart OOO (NSPS / Standards of Performance for Nonmetallic Mineral 

Processing Plants) 

This regulation is not applicable to the Stationary Crusher (211.BF1) because it was constructed 

in 1981, prior to the Subpart OOO applicability date of August 31, 1983. [40 CFR 60.670(e)] 

III.D. 40 CFR, Part 60, Subpart OOO (NSPS / Standards of Performance for Nonmetallic Mineral 

Processing Plants) 

This regulation is not applicable to the Raw Material Transfer (211.BF2) because it was 

constructed in 1981, prior to the Subpart OOO applicability date of August 31, 1983. [40 CFR 

60.670(e)] 

III.E. 40 CFR 63.1350(c), 63.1350(d), Subpart LLL (NESHAP from the Portland Cement 

Manufacturing Industry) 

This regulation is not applicable to the Coal Grinding System (41B.BF2) because it is not an 

affected source as defined in 40 CFR 63.1340. The coal mill is regulated by 40 CFR 60 Subpart 

Y. 

Issued December 1, 2006 Page 52 Title V Operating Permit #2300015002 
Section IV: ACID RAIN PROVISIONS.

This source is not subject to Title IV. This section is not applicable.

Issued December 1, 2006 Page 53 Title V Operating Permit #2300015002 
REVIEWER COMMENTS 

This operating permit incorporates all applicable requirements contained in the following 

documents: 

DAQE-AN0303012-06 dated July 25, 2006 

1. Comment on an item originating in DAQE-AN0303012-06 regarding Kiln & Pre-Calciner 

and Raw Mill (Unit 317.BF1) 

Stack test for PM10: This unit is subject to CAM in the renewal permit. As per 40 CFR 

64.5(d), CAM monitoring satisfies the requirement in 40 CFR 70.6(a)(3)(i)(B) for 

periodic monitoring, but the PM10 stack test frequency specified in the AO remains an 

applicable requirement in Title V. [Comment last updated on 6/29/2006] 

2. Comment on an item originating in this permit regarding Kiln & Pre-Calciner and Raw 

Mill (Unit 317.BF1) 

Additional data collection for optical density (OD) evaluation: The following applies 

to the collection of additional data during the 3-year kiln stack tests to be used for 

evaluating or updating the excursion OD value: 

1. Before obtaining data from COMS, the accuracy and reliability of the COMS shall 

be ensured. At a minimum, the operator shall inspect and verify proper operation of 

the monitor, clean the optical windows, remove any accumulated material from the 

monitor flanges, adjust the monitor calibration to eliminate any drift or offsets, and 

reset zero compensation, if appropriate. The operator shall also conduct a clear path 

calibration of the opacity monitor within 1 month prior to the test and a 

performance audit using external calibrated filters. 

2. Run at least three paired-runs or six consecutive runs for at least 1 hour each 

according to EPA Method 17, Method 5 or ASTM D6831-02. To be acceptable, 

each paired run result shall be within ±2.5 mg/acm of their average. To be 

acceptable, each consecutive run shall be within ±3.0 mg/acm of the average. Runs 

shall be rejected that do not meet the QA specification. All test run results that meet 

the QA requirement shall be used to establish the ODstd. 

3. During each run, the feed rate shall be recorded. Tests shall be conducted at steady 

state conditions (≤ ±10% raw material input variation). 

4. Calculate the emission rate in lb/hr and mg/acm. The emission rate shall be less 

than the permit limit for all runs. 

5. Convert the emission limit in lb/hr to the equivalent PM concentration at actual 

stack conditions using the measured effluent flow rate, stack temperature, stack 

pressure, and effluent moisture concentrations. 

6. Average the 6-minute average optical density readings that correspond to the 

duration of each acceptable PM run. In the event of COMS malfunction during the 

test run, the test shall be terminated. The variation in the optical density during the 

test run shall be ≤ 0.009 OD (2% opacity), otherwise additional test runs shall be 

conducted. 

7. Calculate the optical density equivalent to the standard for each valid test run. 

Average all of the results to determine the new value of ODstd. Compare the 

Issued December 1, 2006 Page 54 Title V Operating Permit #2300015002 
ODstd to 0.097 (20% opacity) and use 0.67ODstd or 0.097, whichever is most 

restrictive. [Comment last updated on 3/29/2006] 

3. Comment on an item originating in DAQE-AN0303012-06 regarding Clinker Cooler (Unit 

419.BF1) 

Stack test for PM10: This unit is subject to CAM in the renewal permit. As per 40 CFR 

64.5(d), CAM monitoring satisfies the requirement in 40 CFR 70.6(a)(3)(i)(B) for 

periodic monitoring, but the PM10 stack test frequency specified in the AO remains an 

applicable requirement in Title V. [Comment last updated on 6/29/2006] 

4. Comment on an item originating in this permit regarding Clinker Cooler (Unit 419.BF1) 

Additional data collection for optical density (OD) evaluation: The following applies 

to the collection of additional data during the 3-year clinker cooler stack tests to be 

used for evaluating or updating the excursion optical density (OD) value: 

1. Before obtaining data from COMS, the accuracy and reliability of the COMS shall 

be ensured. At a minimum, the operator shall inspect and verify proper operation of 

the monitor, clean the optical windows, remove any accumulated material from the 

monitor flanges, adjust the monitor calibration to eliminate any drift or offsets, and 

reset zero compensation, if appropriate. The operator shall also conduct a clear path 

calibration of the opacity monitor within 1 month prior to the test and a 

performance audit using external calibrated filters. 

2. Run at least three paired-runs or six consecutive runs for at least 1 hour each using 

EPA Method 17, Method 5 or ASTM D6831-02. To be acceptable, each paired run 

result shall be within ±2.5 mg/acm of their average. To be acceptable, each 

consecutive run shall be within ±3.0 mg/acm of the average. Reject those runs that 

do not meet the QA specification. All test run results that meet the QA requirement 

shall be used to establish the ODstd. 

3. During each run, the feed rate shall be recorded. Tests shall be conducted at steady 

state conditions (≤ ±10% raw material input variation). 

4. Calculate the emission rate in lb/hr and mg/acm. The emission rate shall be less 

than the permit limit for all runs. 

5. Convert the emission limit in lb/hr to the equivalent PM concentration at actual 

stack conditions using the measured effluent flow rate, stack temperature, stack 

pressure, and effluent moisture concentrations. 

6. Average the 6-minute average optical density readings that correspond to the 

duration of each acceptable PM run. In the event of COMS malfunction during the 

test run, the test shall be terminated. The variation in the optical density during the 

test run shall be ≤ 0.009 OD (2% opacity), otherwise additional test runs shall be 

conducted. 

7. Calculate the optical density equivalent to the standard for each valid test run. 

Average all of the results to determine the new value of ODstd. Compare the 

ODstd to 0.046 (10% opacity) and use the most restrictive value. [Comment last 

updated on 3/01/2006] 

5. Comment on an item originating in this permit regarding Coal Grinding System (Unit 

41B.BF2) 

PM Test Frequency: A PM test frequency of five (5) years has been specified due to a 

low potential for noncompliance with the particulate standard on the thermal dryer. The 

low potential is demonstrated by previous stack test results. Results and percentage of 

limit from previous tests are as follows: 

Issued December 1, 2006 Page 55 Title V Operating Permit #2300015002 
September 2005: 0.0051 gr/dscf PM (16.5%) 

May 2002: 0.00079 gr/dscf PM (2.6%) [Comment last updated on 3/29/2006] 

6. Comment on an item originating in DAQE-AN0303011-05 regarding Limestone Bypass 

System (Unit LBS) 

Removal of notice requirement: The permittee submitted notice to DAQ that the 

referenced emission unit has been installed in a letter dated 12/7/05, and received 

12/12/05. The installation notice requirement for this unit has now been fulfilled, and 

the requirement has been removed from the permit. [Comment last updated on 

6/22/2006] 

7. Comment on an item originating in DAQE-AN0303011-05 regarding Limestone Silo & Belt 

(Unit 512.BF2 and 3) 

Removal of notice requirement: The permittee submitted notice to DAQ that the 

referenced emission unit has been installed in a letter dated 12/7/05, and received 

12/12/05. The installation notice requirement for this unit has now been fulfilled, and 

the requirement has been removed from the permit. [Comment last updated on 

6/22/2006] 

8. Comment on an item originating in DAQE-AN0303011-05 regarding East Clinker Belt 

(Unit 419.BF4) 

Removal of notice requirement: The permittee submitted notice to DAQ, in a letter 

dated 11/17/06, that replacement of the baghouse on the referenced emission unit is not 

going to occur as described in DAQE-AN0303011-05, dated 5/20/05. The permittee’s 

NOI for the redesigned project is currently in process. The notification requirement has 

been removed from the permit. [Comment last updated on 11/28/2006] 

9. Comment on an item originating in DAQE-AN0303011-05 regarding West Clinker Belt 

(Unit 419.BF5) 

Removal of notice requirement: The permittee submitted notice to DAQ, in a letter 

dated 11/17/06, that replacement of the baghouse on the referenced emission unit is not 

going to occur as described in DAQE-AN0303011-05, dated 5/20/05. The permittee’s 

NOI for the redesigned project is currently in process. The notification requirement has 

been removed from the permit. [Comment last updated on 11/28/2006] 

10. Comment on an item originating in this permit regarding optical density in the CAM plans 

[Comment last updated on 11/2/2006]

Sample optical density calculations for informational purposes: 

Optical density relates to opacity through the following equation. 

( )⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

− ⎟ =

⎠

⎞ ⎜

⎝

⎛ = T Opacity

OD

1

1 log 1 log

Where: OD = Optical density 

T = Transmittance or (1 – Opacity), with opacity in decimal form 

Sample calculations for optical density: 

Issued December 1, 2006 Page 56 Title V Operating Permit #2300015002 
Given a measured opacity of 9.1%, optical density becomes, 

041.0

091.01

1 log ⎟ =

⎠

⎞ ⎜

⎝

⎛

− OD =

Given a measured opacity of 10%, optical density becomes, 

046.0

10.01

1 log ⎟ =

⎠

⎞ ⎜

⎝

⎛

− OD =

Additional information can be found in the EPA Handbook, “Continuous Emission 

Monitoring Systems for Non-criteria Pollutants” EPA/625/R-97/001 August 1997, pgs 

43-47. 

Issued December 1, 2006 Page 57 Title V Operating Permit #2300015002